Atmospheric Impact Report

ATMOSPHERIC IMPACT REPORT

In support of the EIA for the proposed Coega 3000 MW Integrated Gas-to-Power Project Zone 13: 1000 MW Inland Power Station

Report issued by: Report issued to: uMoya-NILU Consulting (Pty) Ltd SRK Consulting (South Africa) (Pty) Ltd P O Box 20622 Ground Floor, Bay Suites Durban North, 4016 1a Humewood Rd, Humerail South Africa Port Elizabeth, 6001 South Africa

Report Details

Client: SRK Consulting (South Africa) (Pty) Ltd Report title: Atmospheric Impact Report in support of the EIA for the proposed Coega 3000 MW Integrated Gas-to-Power Project, Zone 13: 1000 MW Inland Power Station Project: uMN457-20 Report number: uMN094-20 Version: Final (20 April 2021) Prepared by: uMoya-NILU Consulting (Pty) Ltd, P O Box 20622, Durban North 4016, South Africa Authors: Mark Zunckel, Atham Raghunandan and Yegeshni Moodley

This report has been produced for SRK Consulting (South Africa) (Pty) Ltd, representing the Coega Development Corporation, by uMoya-NILU Consulting (Pty) Ltd. The intellectual property contained in this report remains vested in uMoya-NILU Consulting (Pty) Ltd. No part of the report may be reproduced in any manner without written permission from uMoya-NILU Consulting (Pty) Ltd, SRK Consulting (South Africa) (Pty) Ltd and Coega Development Corporation.

When used in a reference this document should be cited as follows: uMoya-NILU (2021): Atmospheric Impact Report in support of the EIA for the Proposed Coega 3000 MW Integrated Gas-to-Power Project, Zone 13: Inland Power Station, Report No. uMN094-20, April 2021.

EXECUTIVE SUMMARY

The Coega Development Corporation (CDC) proposes to develop a power project within the Coega Special Economic Zone (SEZ) and the Port of Ngqura including three gas to power plants and associated infrastructure for gas import and distribution.

In accordance with the requirements of the National Environmental Management Act (NEMA) 2014 EIA regulations, as amended, the proposed project requires a full Scoping and EIA process to be conducted. The CDC has appointed SRK Consulting (South Africa) (Pty) Ltd to facilitate the required environmental authorisation process and to conduct an Environmental Impact Assessment (EIA) in terms of the National Environmental Management Act. SRK has appointed uMoya-NILU Consulting (Pty) Ltd to undertake the supporting air quality specialist study for the EIA.

The proposed Coega 3000 MW Integrated Gas-to-Power Project will ultimately include the following components a Liquefied Natural Gas (LNG) terminal and three 1000 MW Gas to Power plants. Two power plants are proposed in Zone 10 (coastal) and one in Zone 13 (inland) of the SEZ. Power generation will be by means of a hybrid of Combined Cycle Gas Turbines (CCGT), Open Cycle Gas Turbines (OCGT), and Reciprocating Engines (RE). Each power plant will use LNG as the primary source of fuel, with diesel and fuel oil as back up fuels. On-site storage of back up fuels will include two 4 000 m³ tanks for diesel and two 4 000 m³ tanks for fuel oil, or 8 000 m3 in total.

The Zone 13: Inland Power Station will have an ultimate generation capacity of 1 000 MW, using piped natural gas to the site. An initial or interim phase of operation using liquid fuels (diesel / HFO) may be required to cover the period until the piped gas supply (CDC gas infrastructure EIA) is available to the site. These options are assessed in this AIR which adheres to the methodology and the regulatory requirement for dispersion modelling studies.

Another option for initial operation of the plant in the absence of piped gas supply is on- site storage and regasification of LNG (4 000 m3). This plant would be 200 MW in capacity. This is the Mulilo-Total development and is assessed in an addendum to this AIR.

Low-sulphur diesel and low-sulphur HFO are relatively clean fuels and emissions from the 130 MW power station are relatively low. The predicted ambient concentrations of

SO2, NO2, PM10, CO and benzene resulting from the power plant emissions are very low. The significance rating for air quality impacts is therefore insignificant for all pollutants.

LNG is a clean fuel. The predicted ambient concentrations of SO2, NO2, PM10, CO and benzene from the power plant emissions are therefore very low. The significance rating for air quality impacts is therefore insignificant for all pollutants.

Ambient monitoring and dispersion modelling show that ambient concentrations of SO2 and NO2 in the Coega SEZ are generally low, but there are some areas where NO2 exceedances occur. PM10 concentrations are relatively high and exceedances of ambient standards were modelled from baseline emission data. The cumulative effect of the initial 130 MW power plant and ultimately of the 1 000 MW power plant will be very small and are highly unlikely to contribute to exceedances of the ambient standards.

The predicted ambient concentrations resulting from the emissions from the CDC project (three 1 000 MW power plants and the infrastructure project) are very low and the intensity is rated as low for NO2 and irrelevant for the other pollutants. It is highly unlikely that they will contribute to exceedances of the ambient standards. The cumulative effect of the CDC project will be very small or negligible.

The cumulative effect of the gas-to-power projects is also predicted to be very small or negligible. The predicted ambient concentrations resulting from the power plant emissions are very low and the intensity is rated as low for NO2 and irrelevant for the other pollutants. It is highly unlikely that they will contribute to exceedances of the ambient standards.

Based on the findings of this assessment for the initial 130 MW liquid fuel fired Zone 13 Inland Power it is recommended that the application be approved. Similarly, based on the findings of this assessment for the ultimate 1 000 MW LNG fired Zone 13 Inland Power it is recommended that the application be approved.

GLOSSARY OF TERMS AND ACRONYMS

AEL Atmospheric Emission Licence AIR Atmospheric Impact Report DEA Department of Environmental Affairs g/s Grams per second HFO Heavy fuel oil kPa Kilo Pascal LNG Liquified Natural Gas MES Minimum Emission Standards mg/hr Milligrams per hour refers to emission rate, i.e. mass per time mg/Nm3 Milligrams per normal cubic meter refers to emission concentration, i.e. mass per volume at normal temperature and pressure, defined as air at 20oC (293.15 K) and 1 atm (101.325 kPa) NAAQS National Ambient Air Quality Standards NEM-AQA National Environment Management: Air Quality Act, 2004 (Act No. 39 of 2004) NEMA National Environmental Management Act, 1998 (Act No. 107 of 1998) USEPA United States Environmental Protection Agency

iii

TABLE OF CONTENTS

EXECUTIVE SUMMARY ...... i TABLE OF CONTENTS ...... iv LIST OF TABLES ...... vi LIST OF FIGURES ...... vii 1. ENTERPRISE DETAILS ...... 1 1.1 Project overview ...... 1 1.2 Enterprise Details ...... 3 1.3 Location and extent of the plant ...... 3 1.3 Description of surrounding landuse (within 5 km radius)...... 4 1.5 Emission Control Officer ...... 5 1.6 Atmospheric Emission Licence (AEL) and Other Authorisations ...... 5 1.6 Modelling contractor ...... 6 1.7 Terms of Reference ...... 6 1.8 Assumptions ...... 7 2. NATURE OF THE PROCESS ...... 7 2.1 Listed Activity or Activities ...... 7 2.2 Process Description ...... 9 2.2.1 Liquefied natural gas (LNG) ...... 10 2.2.2 Power generation ...... 10 2.2.3 Air pollutants resulting from the process ...... 12 2.2.3.1 Overview ...... 12 2.2.3.2 National Ambient Air Quality Standards ...... 12 2.2.3.3 Air pollutants and health implications ...... 13 2.3 Unit Processes...... 17 3. TECHNICAL INFORMATION ...... 18 3.1 Raw Materials Used...... 18 3.2 Appliances and Abatement Equipment Control Technology ...... 18 4. ATMOSPHERIC EMISSIONS ...... 19 4.1 Point Source Parameters ...... 19 4.2 Point Source Maximum Emission Rates (Normal Operating Conditions) ...... 19 4.3 Point Source Maximum Emission Rates (Start Up, Shut-Down, Upset and Maintenance Conditions) ...... 20 4.4 Fugitive Emissions ...... 20 4.5 Emergency Incidents ...... 21 5. IMPACT OF ENTERPRISE ON THE RECEIVING ENVIRONMENT ...... 21 5.1 Baseline conditions ...... 21 5.1.1 Introduction ...... 21 5.1.2 Climate and meteorology ...... 21 5.1.3 Ambient Air Quality ...... 24 5.2 Dispersion Modelling ...... 30 5.2.1 Models used ...... 30 5.2.2 TAPM and CALPUFF parameterisation ...... 31

5.2.3 Model accuracy ...... 33 5.2.4 Background Concentrations and other sources ...... 34 5.2.5 Sensitive Receptors ...... 34 5.2.6 Assessment scenarios ...... 36 5.3 Dispersion Modelling Results ...... 36 5.3.1 Maximum predicted ambient concentrations and sensitive receptor concentrations ...... 36

5.3.1.1 SO2 ...... 36

5.3.1.2 NO2 ...... 42

5.3.1.3 PM10 ...... 45 5.3.1.4 CO ...... 49 5.3.1.5 Benzene ...... 53 5.3.2 Isopleth maps ...... 54

5.3.2.1 Sulphur dioxide (SO2) ...... 54

5.3.2.2 Nitrogen dioxide (NO2) ...... 62

5.3.2.3 Particulates (PM10) ...... 67 5.3.2.4 Carbon monoxide (CO) ...... 72 5.4 Impact Assessment ...... 77 5.4.1 Impact Rating Methodology ...... 77 5.4.2 Summary of Impacts ...... 79 5.5 Analysis of Emissions’ Impact on the Environment ...... 83 6. COMPLAINTS ...... 83 7. CURRENT OR PLANNED AIR QUALITY MANAGEMENT INTERVENTIONS ...... 83 8. COMPLIANCE AND ENFORCEMENT ACTIONS ...... 83 9. SUMMARY AND CONCLUSION ...... 83 10. REFERENCES...... 84 11. FORMAL DECLARATIONS ...... 86

LIST OF TABLES

Table 1: Enterprise details ...... 3 Table 2: Site information ...... 4 Table 3: Current authorisations related to air quality ...... 6 Table 4: Details of the Listed Activities carried out at the Zone 13: Inland Power Station, according to GN 248 (DEA, 2010) and its revisions (DEA, 2013, 2019 and 2020) ...... 8 Table 5: Minimum Emission Standards for Listed Activities according to GN 248 (DEA, 2010) and its revisions (DEA, 2013, 2019 and 2020) ...... 8 Table 6: NAAQS for pollutants relevant to the Inland Power Station. Values in brackets are effective from 1 Jan 2030 ...... 13 Table 7: Unit processes at the Zone 13: Inland Power Station...... 17 Table 8: Raw material used at the proposed gas to power plant ...... 18 Table 9: Production rate ...... 18 Table 10: Energy sources used ...... 18 Table 11: Appliances and abatement equipment and control technology ...... 19 Table 12: Location of stack and stack parameters ...... 19 Table 13: Power station stack emission concentrations and emission rates ...... 19 Table 14: Tanks benzene emissions (kg/annum) ...... 20 Table 15: Annual average monitored concentrations ...... 25

Table 16: Maximum predicted baseline ambient annual SO2, NO2 and PM10 concentrations in µg/m3 and the predicted 99th percentile concentrations for 24-hour and 1-hour, with the South African NAAQS ...... 27 Table 17: Parameterisation of key variables for CALMET...... 33 Table 18: Parameterisation of key variables for CALPUFF ...... 33 3 Table 19: Maximum predicted ambient annual SO2 concentrations in µg/m and the predicted 99th percentile concentrations for 24-hour and 1-hour, with the South African NAAQS ...... 37

Table 20: Predicted maximum annual average, 24-hour and 1-hour SO2 concentrations in µg/m3 at the sensitive receptors for the two 130 MW scenarios ...... 38

Table 21: Predicted maximum annual average, 24-hour and 1-hour SO2 concentrations in µg/m3 at the sensitive receptors for the four 1 000 MW scenarios ...... 40 3 Table 22: Maximum predicted ambient annual NO2 concentrations in µg/m and the predicted 99th percentile concentrations for 1-hour with the South African NAAQS ...... 42 3 Table 23: Predicted maximum annual average and 1-hour NO2 concentrations in µg/m at the sensitive receptors for the two 130 MW scenarios ...... 43 3 Table 24: Predicted maximum annual average and 1-hour NO2 concentrations in µg/m at the sensitive receptors for the four 1 000 MW scenarios ...... 44 3 Table 25: Maximum predicted ambient annual PM10 concentrations in µg/m and the predicted 99th percentile concentrations for 24-hour with the South African NAAQS ...... 46

3 Table 26: Predicted maximum annual average and 24-hour PM10 concentrations in µg/m at the sensitive receptors for the two 130 MW scenarios ...... 46 3 Table 27: Predicted maximum annual average and 24-hour PM10 concentrations in µg/m at the sensitive receptors for the four 1 000 MW scenarios ...... 48 Table 28: Maximum predicted ambient 8-hour and 1-hour CO concentrations in µg/m3 with the South African NAAQS ...... 50 Table 29: Predicted maximum 8-hour and 1-hour CO concentrations in µg/m3 at the sensitive receptors for the two 130 MW scenarios ...... 50 Table 30: Predicted maximum 8-hour and 1-hour CO concentrations in µg/m3 at the sensitive receptors for the four 1 000 MW scenarios ...... 51 Table 31: Maximum predicted annual benzene concentrations in µg/m3 with the South African NAAQS ...... 53 Table 32: Criteria used to determine the Consequence of the Impact ...... 77 Table 33: Method used to determine the Consequence Score ...... 77 Table 34: Probability Classification ...... 78 Table 35: Impact Significance Ratings ...... 78 Table 36: Impact status and confidence classification ...... 78 Table 37: Air quality Impact Assessment summary scores ...... 82

LIST OF FIGURES

Figure 1: Proposed layout of the Coega 3000 MW Integrated Gas-to-Power Project ...... 2 Figure 2: Relative location of the Zone 13: Inland Power Station (Google Earth, 2017) .. 5 Figure 3: Schematic process diagram for an Open-Cycle gas turbine (top) and a Closed- Cycle gas turbine (bottom) (Carnegie Energie, 2019) ...... 11 Figure 4: A flow diagram for power generation with engines (left), and a bank of engines connected in series ...... 12 Figure 5:Average of daily minimum, maximum and mean temperatures (°C) and average monthly precipitation (mm) at Port Elizabeth Airport for the period 1961 – 1990...... 21 Figure 6: Annual wind roses for Port Elizabeth Airport, Amsterdamplein, Motherwell and Saltworks for 2009-2011. Arcs represent 5% frequency intervals...... 23

Figure 7: a) 1-hr and b) 24-hr average SO2 monitored concentrations ...... 24

Figure 8: 1-hr average NO2 monitored concentrations ...... 25

Figure 9: 24-hr average PM10 monitored concentrations ...... 25 Figure 10: Industrial Sources ...... 26 Figure 11: Modelled baseline annual average (top), 99th percentile of 24-hour (middle) 3 and of 1-hour (bottom) SO2 concentrations in the Coega SEZ in µg/m ...... 28 Figure 12: Modelled baseline annual average (top) and 99th percentile of 1-hour 3 (bottom) NO2 concentrations in the Coega SEZ in µg/m ...... 29 Figure 13: Modelled baseline annual average (top) and 99th percentile of 24-hour 3 (bottom) PM10 concentrations in the Coega SEZ in µg/m ...... 30

vii

Figure 14: Proposed location of the modelling domains for TAPM and CALPUFF modelling ...... 32 Figure 15: Selected sensitive receptors ...... 35 3 Figure 16: Predicted annual average SO2 concentrations in µg/m for Scenario 1 the 130 MW Power Station (top) and Scenario 2 the 130 MW Power Station with baseline (bottom) ...... 56 th 3 Figure 17: Predicted 99 percentile of the 24-hour SO2 concentrations in µg/m for Scenario 1 the 130 MW Power Station (top) and Scenario 2 the 130 MW Power Station with baseline (bottom) ...... 57 th 3 Figure 18: Predicted 99 percentile of the 1-hour SO2 concentrations in µg/m for Scenario 1 the 130 MW Power Station (top) and Scenario 2 the 130 MW Power Station with baseline (bottom) ...... 58 3 Figure 19: Predicted annual average SO2 concentrations in µg/m for Scenario 3 the 1 000 MW Power Station (top left), Scenario 4 the 1 000 MW Power Station with baseline (top right), Scenario 5 the 3 000 MW Coega G2P Project (bottom left) and Scenario 6 the 3 000 MW Coega G2P Project and baseline (bottom right) ...... 59 th 3 Figure 20: Predicted 99 percentile of the 24-hour SO2 concentrations in µg/m for Scenario 3 the 1 000 MW Power Station (top left), Scenario 4 the 1 000 MW Power Station with baseline (top right), Scenario 5 the 3 000 MW Coega G2P Project (bottom left) and Scenario 6 the 3 000 MW Coega G2P Project and baseline (bottom right) ...... 60 th 3 Figure 21: Predicted 99 percentile of the 1-hour SO2 concentrations in µg/m for Scenario 3 the 1 000 MW Power Station (top left), Scenario 4 the 1 000 MW Power Station with baseline (top right), Scenario 5 the 3 000 MW Coega G2P Project (bottom left) and Scenario 6 the 3 000 MW Coega G2P Project and baseline (bottom right) ...... 61 3 Figure 22: Predicted annual average NO2 concentrations in µg/m for Scenario 1 the 130 MW Power Station (top) and Scenario 2 the 130 MW Power Station with baseline (bottom) ...... 63 th 3 Figure 23: Predicted 99 percentile of the 1-hour NO2 concentrations in µg/m for Scenario 1 the 130 MW Power Station (top) and Scenario 2 the 130 MW Power Station with baseline (bottom) ...... 64 3 Figure 24: Predicted annual average NO2 concentrations in µg/m for Scenario 3 the 1 000 MW Power Station (top left), Scenario 4 the 1 000 MW Power Station with baseline (top right), Scenario 5 the 3 000 MW Coega G2P Project (bottom left) and Scenario 6 the 3 000 MW Coega G2P Project and baseline (bottom right) ...... 65 th 3 Figure 25: Predicted 99 percentile of the 1-hour NO2 concentrations in µg/m for Scenario 3 the 1 000 MW Power Station (top left), Scenario 4 the 1 000 MW Power Station with baseline (top right), Scenario 5 the 3 000 MW Coega G2P Project (bottom left) and Scenario 6 the 3 000 MW Coega G2P Project and baseline (bottom right) ...... 66

viii

3 Figure 26: Predicted annual average PM10 concentrations in µg/m for Scenario 1 the 130 MW Power Station (top) and Scenario 2 the 130 MW Power Station with baseline (bottom) ...... 68 th 3 Figure 27: Predicted 99 percentile of the 24-hour PM10 concentrations in µg/m for Scenario 1 the 130 MW Power Station (top) and Scenario 2 the 130 MW Power Station with baseline (bottom) ...... 69 3 Figure 28: Predicted annual average PM10 concentrations in µg/m for 1) for Scenario 3 the 1 000 MW Power Station (top left), Scenario 4 the 1 000 MW Power Station with baseline (top right), Scenario 5 the 3 000 MW Coega G2P Project (bottom left) and Scenario 6 the 3 000 MW Coega G2P Project and baseline (bottom right) ...... 70 th 3 Figure 29: Predicted 99 percentile of the 24-hour PM10 concentrations in µg/m for Scenario 3 the 1 000 MW Power Station (top left), Scenario 4 the 1 000 MW Power Station with baseline (top right), Scenario 5 the 3 000 MW Coega G2P Project (bottom left) and Scenario 6 the 3 000 MW Coega G2P Project and baseline (bottom right) ...... 71 Figure 30: Predicted 8-hour CO concentrations in µg/m3 for Scenario 1 the 130 MW Power Station (top) and Scenario 2 the 130 MW Power Station with baseline (bottom) ...... 73 Figure 31: Predicted 1-hour CO concentrations in µg/m3 for Scenario 1 the 130 MW Power Station (top) and Scenario 2 the 130 MW Power Station with baseline (bottom) ...... 74 Figure 32: Predicted 8-hour CO concentrations in µg/m3 for Scenario 3 the 1 000 MW Power Station (top left), Scenario 4 the 1 000 MW Power Station with baseline (top right), Scenario 5 the 3 000 MW Coega G2P Project (bottom left) and Scenario 6 the 3 000 MW Coega G2P Project and baseline (bottom right) .... 75 Figure 33: Predicted 1-hour CO concentrations in µg/m3 for Scenario 3 the 1 000 MW Power Station (top left), Scenario 4 the 1 000 MW Power Station with baseline (top right), Scenario 5 the 3 000 MW Coega G2P Project (bottom left) and Scenario 6 the 3 000 MW Coega G2P Project and baseline (bottom right) .... 76

1. ENTERPRISE DETAILS

1.1 Project overview

The proposed Coega 3000 MW Integrated Gas-to-Power Project will ultimately include the following components:

i. A Liquefied Natural Gas (LNG) terminal, consisting of a berth with off-loading arms within the Port of Ngqura, cryogenic pipelines, storage and handling facilities and regasification modules. Initially a floating storage and regasification unit in the Port of Ngqura is proposed, followed by land-based storage and regasification as the economics of the project merit the investment in this infrastructure.

ii. Three 1000 MW Gas to Power plants. Two power plants are proposed in Zone 10 (coastal) and one in Zone 13 (inland) of the SEZ. Power generation will be by means of a hybrid of Combined Cycle Gas Turbines (CCGT), Open Cycle Gas Turbines (OCGT), and Reciprocating Engines (RE). Each power plant will use LNG as the primary source of fuel, with diesel and fuel oil as back up fuels. On-site storage of back up fuels will include two 4 000 m³ tanks for diesel and two 4 000 m³ tanks for fuel oil.

iii. Gas pipelines for the transmission, distribution, and reticulation of natural gas from the ship off loading berth to the power plants and to a designated off take point for road transport of LNG & Natural Gas (NG).

The proposed layout of the project components is shown in Figure 1.

Environmental Authorisation will be sought for each project. This AIR supports the application for the Zone 13: Inland Power Station and the on-site liquid fuel storage tanks. It firstly considers the initial generation scenario of 130 MW liquid fuel (diesel or HFO), and secondly the ultimate generation scenario of 1 000 MW using LNG.

Figure 1: Proposed layout of the Coega 3000 MW Integrated Gas-to-Power Project

1.2 Enterprise Details

The enterprise details for the Coega Development Corporation (CDC) are listed in Table 1.

Table 1: Enterprise details Entity Name: Coega Development Corporation Trading as: Coega Development Corporation Type of Enterprise, e.g. Company/Close Corporation Corporation/Trust, etc.: Company/Close Corporation/Trust Registration Number 82003891/07 (Registration Numbers if Joint Venture): Corner Alcyon & Zibuko St, Zone 1, Coega SEZ, Registered Address: Port Elizabeth, 6100 Postal Address: Pvt Bag X6009, Port Elizabeth Telephone Number (General): 041 4030421 Fax Number (General): 041 4030401 Company Website: Industry Type/Nature of Power generation Trade: Land Use Zoning as per Town Industrial Planning Scheme: Land Use Rights if outside N/A Town Planning Scheme: Responsible Person: Mr Sadiek Davids Emissions Control Officer: To be appointed Telephone Number: 041403 0400 Cell Phone Number: 084570 2849 Fax Number: 041 4030401 Email Address: [email protected] After Hours Contact Details: As above

1.3 Location and extent of the plant

The site information relating to the proposed Coega 3000 MW Integrated Gas-to-Power Project’s Inland Power Station in Zone 13 is listed in Table 2.

Table 2: Site information Dan Pienaar St, Zone 13 of the Physical Address of the Licensed Premises: Coega Special Economic Zone (SEZ) Zone 13 of the Coega Special Description of Site: Economic Zone (SEZ) Property Registration Number (Surveyor- Erf 329 General Code): Coordinates (latitude, longitude) of Latitude: - 33.745871 ° Approximate Centre of Operations (Decimal Longitude: 25.682247 ° Degrees): Coordinates (UTM) of Approximate Centre Easting: 377943 m E of Operations: Northing: 6265241 m S Extent (km²): 0.18 km² Elevation Above Mean Sea Level (m): 68 m Province: Eastern Cape Nelson Mandela Bay Metropolitan District/Metropolitan Municipality: Municipality Local Municipality: N/A Designated Priority Area (if applicable): N/A

1.3 Description of surrounding landuse (within 5 km radius)

The proposed project site is currently a Greenfield location in Zone 13 of the Coega SEZ (Figure 1 and Figure 2). The Coega SEZ is located within the Nelson Mandela Bay Municipality (NMBM). There are no residences within the SEZ, so human exposure to emissions from the proposed power station is limited to the industries and businesses that operate at the Coega SEZ and the adjacent Markman industrial area.

According to the USEPA, sensitive receptors include, but are not limited to, hospitals, schools, day care facilities, elderly housing and convalescent facilities. These are areas where the occupants are more susceptible to the adverse effects of exposure to toxic chemicals, pesticides, and other pollutants. Extra care must be taken when dealing with contaminants and pollutants close to areas recognised as sensitive receptors.

Industrial areas may be classified as receptors, but not necessarily sensitive receptors. Higher pollutant concentrations are normally expected in industrial areas and this is reflected in the NAAQS (e.g. dust fallout limit value of 1 200 mg/m2/day for industrial areas versus 600 mg/m2/day for residential areas).

The closest residential area to the proposed site is Motherwell, which is adjacent to the south-western border of the SEZ, approximately 2.3 km from the project site. Motherwell is a densely populated township with a total population of approximately 130 000, or 4 000

inhabitants per square kilometre. Motherwell is identified as a sensitive receptor due to the presence of schools, hospitals, crèches, etc.

Another residential area, Wells Estate, is located on the southern border of the SEZ, approximately 4.2 km from the proposed site. This is a smaller area with substantially fewer residents. Further south is Bluewater Bay, located approximately 7 km away. All other residential areas are located more than 10 km away from the power plant site.

Figure 2: Relative location of the Zone 13: Inland Power Station (Google Earth, 2017)

1.5 Emission Control Officer

The Power Station Manager will be the Emission Control Officer (ECO). This position does not yet exist.

1.6 Atmospheric Emission Licence (AEL) and Other Authorisations

An Atmospheric Emissions Licence (AEL) nor any other authorisations have been issued for the proposed Zone 13: Inland Power Station of the Coega 3000 MW Gas-to-Power Project (Table 3).

Table 3: Current authorisations related to air quality Atmospheric Date of Listed Category Listed Activity Process Emission Registration Activity of Listed Description License Certificate Subcategory Activity No record

1.6 Modelling contractor

The dispersion modelling for this AIR is conducted by:

Company: uMoya-NILU Consulting (Pty) Ltd Modellers: Dr Mark Zunckel and Atham Raghunandan Contact details: Tel: 031 262 3265 Cell: 083 690 2728 email: [email protected] or [email protected]

1.7 Terms of Reference

The application for Environmental Authorisation for the proposed 3 000 MW Coega Gas-to- Power Project will be split into four separate applications. Therefore, separate AIRs will be compiled for each power plant and for the gas infrastructure (i.e. a total of four AIRs).

The terms of reference for the Atmospheric Impact Reports (AIRs) are to: • Conduct a baseline assessment. • Describe the sources of emissions and compile of an emission inventory for each of the proposed facilities. • Conduct dispersion modelling for key pollutants identified in the emissions inventory to predict ambient concentrations and present these as isopleths on a base map of the surrounding area. • Assess impacts on ambient air quality during construction, operation, and decommissioning phases of the projects. • Identify operating conditions (e.g. start-up & maintenance) that may lead to ‘abnormal’ air emissions. • Recommend management and mitigation measures (including optimal height of stacks) associated with impacts from the proposed power plants. • Assess cumulative impacts on ambient air quality, with reference to the additional emissions each power plant will add.

1.8 Assumptions

The following assumptions are relevant to this AIR:

a) No ambient monitoring is done in this assessment, rather available ambient air quality data is used. b) The Model Plan of Study (uMoya-NILU, 2020) describes the dispersion modelling methodology and has been accepted by the Licensing Authority. c) The worse-case scenario is assessed by applying the highest Minimum Emission Standards between those for gas turbines and reciprocating engines. d) The potential air quality impacts of the proposed Zone 13: Inland Power Station is assessed for the plant only, for the plant with existing air pollution sources in the Coega SEZ, and the plant with other gas-to-power applications. e) The assessment of potential human health impacts is based on predicted (modelled)

ambient concentrations of SO2, NO2, CO, PM10 and benzene and health-based NAAQS.

2. NATURE OF THE PROCESS

2.1 Listed Activity or Activities

As a measure to reduce emissions from industrial sources and to improve ambient air quality, Listed Activities and associated Minimum Emission Standards (MES) were published in 2010 in Government Notice 248 (DEA, 2010) and revised in 2013 (Government Notice 893, DEA, 2013), in 2019 (Government Notice 867, DEA, 2019) and in 2020 (Government Notice 657, DEA, 2020).

Zone 13 Inland Power Plant: 1000 MW gas to power plant based on Air Cooling with options of Combined Cycle and Open Cycle options on Gas Turbines and Gas Reciprocating Engines.

The combustion of gaseous fuel for steam production or electricity is a Listed Activity. The storage of liquid fuels over a specified storage capacity is also a Listed Activity. The definition of the Listed Activity is shown in Table 4. The MES for Sub-categories are listed in Table 5.

Table 4: Details of the Listed Activities carried out at the Zone 13: Inland Power Station, according to GN 248 (DEA, 2010) and its revisions (DEA, 2013, 2019 and 2020)

Category of Listed Sub-category of the Application Activity Listed Activity

Category 1: Combustion Sub-category 1.4: Gas All installations with design Installations combustion (including gas capacity equal to or greater than turbines burning natural 50 MW heat input per unit, based gas) used primarily for on the lower calorific value of the steam raising or electricity fuel used generation Sub-category 1.5: Liquid All installations with design and gas fuel stationary capacity equal to or greater than engines used for electricity 10 MW heat input per unit, based generation on the lower calorific value of the fuel used Category 2: Petroleum Sub-category 2.4: Storage All permanent immobile liquid industry, the production and Handling of Petroleum storage facilities at a single site of gaseous and liquid Products with a combined storage capacity greater than 1000 m3. fuels as well as petrochemicals from crude oil, coal, gas or biomass

Table 5: Minimum Emission Standards for Listed Activities according to GN 248 (DEA, 2010) and its revisions (DEA, 2013, 2019 and 2020) Substance or mixture of substances Minimum Emission Standards (mg/Nm3)

under normal conditions of 15% O2, 273 Common name Chemical symbol Kelvin and 101.3 kPa. 1.4: Gas combustion Particulate matter N/A 10 a Oxides of nitrogen NOX 50

Sulphur dioxide SO2 400 1.5: Reciprocating engines Liquid fuels Gaseous fuels Particulate matter N/A 50 50 a Oxides of nitrogen NOX 2 000 400

Sulphur dioxide SO2 1 170 0 a: expressed as NO2 2.4: Storage and Handling of Petroleum Products Application All permanent immobile liquid Storage facilities at a single site with a combined storage capacity of greater than 1 000 m3 True vapour pressure of Type of tank or vessel contents at product

storage temperature Type 1: Up to 14 kPa Fixed-roof tank vented to atmosphere, or as per Type 2 and 3 Type 2: Above 14 kPa and Fixed-roof tank with Pressure Vacuum Vents fitted as a minimum, up to 91 kPa with a to prevent "breathing" losses, or as per Type 3 throughput of less than 50 000 m3 per annum Type 3: Above 14 kPa and a) External floating-roof tank with primary rim seal and up to 91 kPa with a secondary rim seal for tank with a diameter greater than 20 m, throughput greater than 50 or 000 m3 per annum b) fixed-roof tank with internal floating deck / roof fitted with primary seal, or c) fixed-roof tank with vapour recovery system. Type 4: Above 91 kPa Pressure vessel Description: Vapour Recovery Units Application: All loading/ offloading facilities with a throughput greater than 50 000 m3 Substance or mixture of Plant mg/Nm3 under normal conditions of substances status 273 Kelvin and 101.3 kPa Common Name Chemical Symbol Total volatile organic N/A New 150 compounds from vapour recovery/ Existing 150 destruction units using thermal treatment Total volatile organic N/A New 40 000 compounds from vapour Existing 40 000 recovery/ destruction units using non-thermal treatment

2.2 Process Description

2.2.1 Diesel and HFO

Diesel and Heavy Fuel Oil (HFO) are refined liquid fuels. They are similar fuels and consist primarily of hydrocarbons with smaller amounts of hydrogen, nitrogen, sulphur, and volatile organic compounds. Diesel has a sulphur content of 500 ppm or less. Low-sulphur HFO has a sulphur content of less than 2%. Combustion of diesel of HFO results in emissions of

oxides of nitrogen (NO and NO2, referred to as NOX), carbon monoxide (CO), sulphur dioxide (SO2) and particulates.

2.2.2 Liquefied natural gas (LNG)

Natural gas used for energy generation is primarily methane, with low concentrations of other hydrocarbons, water, carbon dioxide, nitrogen, oxygen and some sulphur compounds. Liquefied Natural Gas (LNG) is natural gas which has been cooled below its boiling point (- 161°C) in a process known as liquefaction. The process of liquefaction involves extracting most of the impurities in raw natural gas. The remaining natural gas is primarily methane with only small amounts of other hydrocarbons and consequently is widely considered a clean fossil fuel.

2.2.3 Power generation

Power generation options are Combined Cycle and Open Cycle options on Gas Turbines and Gas Reciprocating Engines.

Open cycle refers to a power generation configuration in which the heat in exhaust gases is not utilised for energy production (Figure 3). Closed cycle refers to a power generation configuration in which the waste energy in the hot exhaust gases is captured, by means of a heat exchanger, and converted to electricity (Figure 3).

Combustion engines used for electric power generation are internal combustion engines in which an air-fuel mixture is compressed by a piston and ignited within a cylinder. Dual-fuel engines are designed with the ability to burn both liquid and gaseous fuels. When operating in gas mode, the gaseous fuel is premixed with air, injected just after the compression stroke and ignited by a pilot fuel flame. In this process, the pilot fuel flame acts a “spark plug” to ignite the lean gas-air mixture. Dual-fuel DF engines retain the ability to use a backup liquid fuel when gas supply is interrupted. A flow diagram for combustion engines and a typical bank of engines at a power plant is shown in Figure 4.

Gas turbines are more efficient than gas engines at higher production capacities, however gas engines allow greater flexibility in terms of changing load and start up efficiency. While the maximum unit size of engines is limited to 12 MW, multiple engine units could be connected in series to meet the capacity requirements, although the space required will exceed that of gas turbines for the same generation capacity.

The power plant will transfer power into 400 kV powerlines located in the power line servitude.

A small tank farm storing backup fuels of diesel and fuel oil is also included on-site, in the event of LNG being unavailable for abnormal operating conditions, such as start-up.

Figure 3: Schematic process diagram for an Open-Cycle gas turbine (top) and a Closed-Cycle gas turbine (bottom) (Carnegie Energie, 2019)

Figure 4: A flow diagram for power generation with engines (left), and a bank of engines connected in series

2.2.4 Air pollutants resulting from the process

2.2.3.1 Overview

The quantity and nature of emissions to the atmosphere from LNG combustion depends on the quality of the fuel, fuel consumption, the combustion device, and the air pollution control devices.

The combustion of LNG included results in gaseous emissions of sulphur dioxide (SO2),

oxides of nitrogen (NO + NO2 = NOX), carbon monoxide (CO), and some particulate

matter (PM). Carbon dioxide (CO2) is the main Greenhouse Gases resulting from LNG combustion.

SO2 is produced from the combustion of sulphur in the LNG. NOX is produced from thermal fixation of atmospheric nitrogen in the combustion flame and from oxidation

of nitrogen bound in the LNG. The quantity of NOx produced is directly proportional to the temperature of the flame. The non-combustible portion of the fuel remains as solid waste and emitted as particulates.

Back-up fuels stored on-site can generate VOC’s such as benzene, toluene, ethyl benzene and xylene from storage and transportation losses.

2.2.3.2 National Ambient Air Quality Standards

The effects of air pollutants on human health occur in different ways of ways with short-term, or acute effects, and chronic, or long-term, effects. Different groups of people are affected differently, depending on their level of sensitivity, with the

elderly and young children being more susceptible. Factors that link the concentration of an air pollutant to an observed health effect are the concentration and the duration of the exposure to that particular air pollutant.

Criteria pollutants occur ubiquitously in urban and industrial environments. Their effects on human health and the environment are well documented by the World Health Organisation (WHO) (e.g. WHO, 1999; 2003; 2005). South Africa has

accordingly established NAAQS for SO2, NO2, CO, respirable particulate matter

(PM10), amongst others (DEA, 2009).

The NAAQS consists of a ‘limit’ value and a permitted frequency of exceedance. The limit value is the fixed concentration level aimed at reducing the harmful effects of a pollutant. The permitted frequency of exceedance represents the acceptable number of exceedances of the limit value expressed as the 99th percentile. Compliance with the ambient standard implies that the frequency of exceedance of the limit value does not exceed the permitted tolerance. Being a health-based standard, ambient concentrations below the standard imply that air quality poses an acceptable risk to human health, while exposure to ambient concentrations above the standard implies

that there is an unacceptable risk to human health. The NAAQS for PM10, NOX, SO2, CO and benzene are presented in Table 13.

Table 6: NAAQS for pollutants relevant to the Inland Power Station. Values in brackets are effective from 1 Jan 2030 Pollutant Averaging period Limit value (µg/m3) Tolerance

SO2 1 hour 350 88 24 hour 125 4 1 year 50 0

NO2 1 hour 200 88 1 year 40 0

CO 1-hour 30 000 88 8-hour running mean 10 000 11

PM10 24 hour 75 4 1 year 40 0

PM2..5 24 hour 40 (25) 0 1 year 20 (15) 0 Benzene Annual 5 0

CO2 is a Greenhouse Gas, therefore ambient air quality standards do not apply. However, it is a priority pollutant (DEA, 2016). Emissions must be accounted for and reported.

2.2.3.3 Air pollutants and health implications

The sections below provide a literature review of these pollutants from an air quality and human health perspective.

Sulphur dioxide (SO2)

Dominant sources of SO2 include fossil fuel combustion from industry and power plants. SO2 is emitted when coal is burnt for energy. The combustion of fuel oil also results in high SO2 emissions. Domestic coal or kerosene burning can thus also result in the release of SO2. Motor vehicles also emit SO2, in particular diesel vehicles due to the higher sulphur content of diesel fuel. Smelting of mineral ores can also result in the production of SO2, because metals usually exist as sulphides within the ore.

On inhalation, most SO2 only penetrates as far as the nose and throat, with minimal amounts reaching the lungs, unless the person is breathing heavily, breathing only through the mouth, or if the concentration of SO2 is high (CCINFO, 1998). The acute response to SO2 is rapid, within 10 minutes in people suffering from asthma (WHO, 2005). Effects such as a reduction in lung function, an increase in airway resistance, wheezing and shortness of breath, are enhanced by exercise that increases the volume of air inspired, as it allows SO2 to penetrate further into the respiratory tract

(WHO, 1999). SO2 reacts with cell moisture in the respiratory system to form sulphuric acid. This can lead to impaired cell function and effects such as coughing, broncho-constriction, exacerbation of asthma and reduced lung function. For example an exposure of 5 to 10 min to 200 to 300 ppb (520 to 780 µg/m3) may reduce lung function (measured as Forced Expiratory Volume in the first second

(FEV1)) by more than 15% (US-EPA, 2009). There is however, uncertainty about 3 exposure-response effects below concentrations of 200 ppb (520 µg/m ). For SO2 exposure short-term peak concentrations are therefore important (US-EPA, 2009).

Re-analysis of the effects of SO2 done post-2005 has found evidence to suggest that the point of departure for setting the 10-minute guideline needs an additional uncertainty factor, which indicates that the guideline may have to be lowered when it is re-evaluated (WHO, 2013).

Nitrogen dioxide (NO2)

Nitrogen dioxide (NO2) and nitric oxide (NO) are formed simultaneously in combustion processes and other high temperature operations such as metallurgical furnaces, blast furnaces, plasma furnaces, and kilns. NOX is a term commonly used to refer to the combination of NO and NO2. NOX can also be released from nitric acid plants and other types of industrial processes involving the generation and/or use of nitric acid. NOX also forms naturally through de-nitrification by anaerobic bacteria in soils and plants. Lightning is also a source of NOX.

The route of exposure to NO2 is inhalation and the seriousness of the effects depend more on the concentration than on the length of exposure. The site of deposition for

NO2 is the distal lung where NO2 reacts with moisture in the fluids of the respiratory tract to form nitrous and nitric acids. About 80 to 90% of inhaled nitrogen dioxide is absorbed through the lungs (CCINFO, 1998). Nitrogen dioxide (present in the blood as the nitrite ion) oxidises unsaturated membrane lipids and proteins, which then

results in the loss of control of cell permeability. Nitrogen dioxide causes decrements in lung function, particularly increased airway resistance. Inflammatory reactions were observed at NO2 concentrations between 200 and 1000 ppb (380 to 1880 µg/m3) when individuals were exposed under controlled conditions for periods that varied between 15 minutes and six hours (WHO, 2013). However, the results had been inconsistent below 1000 ppb but were much more evident at concentrations higher than 1000 ppb (1880 µg/m3) (WHO, 2013). Below 1000 ppb healthy individuals did not show inflammatory reactions and for those with respiratory diseases (asthma and chronic obstructive pulmonary disease), inflammation was not induced below 600 ppb, except for one study that reported individuals responded at 260 ppb (500 µg/m3) (Hesterberg et al., 2009). A review study (on 50 publications) published in 2009 by Hesterberg et al. focussed on short- term exposure to NO2 and adverse health effects on humans. The authors came to the conclusion that a short-term exposure standard of not more than 200 ppb would protect all individuals, including sensitive individuals. People with chronic respiratory problems and people who work or exercise outside will be more at risk to NO2 exposure.

Chronic exposure to NO2 increases susceptibility to respiratory infections (WHO,

1997). However, a review study of 50 publications found no consistent evidence that short-term exposure below 200 ppb increased susceptibility to viral infections (Hesterberg et al., 2009).

The WHO has reviewed hundreds of studies published between 2004 and 2011 on adverse health effects after short-term and long-term exposure to NO2 (WHO, 2013). The health effects from short-term exposure are more evident than those from long- term (chronic) exposure, because in many studies a high correlation was found between NO2 and other pollutants (WHO, 2013). However, some epidemiology studies suggested an association between NO2 and respiratory mortality and an association with respiratory effects in children, including effects on children’s lung function (WHO, 2013).

Particulate Matter

Particulate Matter (PM) is a broad term used to describe the fine particles found in the atmosphere, including soil dust, dirt, soot, smoke, pollen, ash, aerosols and liquid droplets. With PM, it is not just the chemical composition that is important but also the particle size. Particle size has the greatest influence on the behaviour of PM in the atmosphere with smaller particles tending to have longer residence times than larger ones. PM is categorised, according to particle size, into TSP, PM10 and PM2.5.

Total suspended particulates (TSP) consist of all particles smaller than 100 µm suspended within the air. TSP is useful for understanding nuisance effects of PM, e.g. settling on houses, deposition on and discolouration of buildings, and reduction in visibility.

PM10 describes all particulate matter in the atmosphere with a diameter equal to or less than 10 µm. Sometimes referred to simply as coarse particles, they are generally emitted from motor vehicles, factory and utility smokestacks, construction sites, tilled fields, unpaved roads, stone crushing, and burning of wood. Natural sources include sea spray, windblown dust and volcanoes. Coarse particles tend to have relatively short residence times as they settle out rapidly and PM10 is generally found relatively close to the source except in strong winds.

PM2.5 describes all particulate matter in the atmosphere with a diameter equal to or less than 2.5 µm. They are often called fine particles, and are mostly related to combustion (motor vehicles, smelting, incinerators), rather than mechanical processes as is the case with PM10. PM2.5 may be suspended in the atmosphere for long periods and can be transported over large distances. Fine particles can form in the atmosphere in three ways: when particles form from the gas phase, when gas molecules aggregate or cluster together without the aid of an existing surface to form a new particle, or from reactions of gases to form vapours that nucleate to form particles.

Particulate matter may contain both organic and inorganic pollutants. The extent to which particulates are considered harmful depends on their chemical composition and size, e.g. particulates emitted from diesel vehicle exhausts mainly contain unburned fuel oil and hydrocarbons that are known to be carcinogenic. Very fine particulates pose the greatest health risk as they can penetrate deep into the lung, as opposed to larger particles that may be filtered out through the airways’ natural mechanisms.

In normal nasal breathing, particles larger than 10 μm are typically removed from the air stream as it passes through the nose and upper respiratory airways, and particles between 3 μm and 10 μm are deposited on the mucociliary escalator in the upper airways. Only particles in the range of 1 μm to 2 μm penetrate deeper where deposition in the alveoli of the lung can occur (WHO, 2003). Coarse particles (PM10 to PM2.5) can accumulate in the respiratory system and aggravate health problems such as asthma. PM2.5, which can penetrate deeply into the lungs, are more likely to contribute to the health effects (e.g. premature mortality and hospital admissions) than coarse particles (WHO, 2003).

The WHO has reviewed many studies since 2005 to update information on health effects on PM (WHO, 2013). Studies have once again confirmed that PM (not only

PM10 but fine and ultra-fine PM as well), has short and long-term (both immediate and delayed) adverse health effects such as cardiovascular effects, but new associations with diseases such as atherosclerosis (thickening of artery walls), birth defects and respiratory illness in children have also been found (WHO, 2013). In addition, some studies have suggested a possible link between PM and diabetes and effects on the central nervous system (WHO, 2013). The increase in daily mortality

(between 0.4% and 1%) from exposure to PM10 was also confirmed in several studies since 2005 (WHO, 2013).

Carbon monoxide

CO is an odourless, colourless and toxic gas. People with pre-existing heart and respiratory conditions, blood disorders and anaemia are sensitive to the effects of CO. Health effects of CO are mainly experienced in the neurological system and the cardiovascular system (WHO, 1999). The binding of CO with haemoglobin reduces the oxygen-carrying capacity of the blood and impairs the release of oxygen from haemoglobin to extravascular tissues. These are the main causes of tissue hypoxia produced by CO at low exposure levels. The toxic effects of CO become evident in organs and tissues with high oxygen consumption such as the brain, the heart, exercising skeletal muscle and the developing fetus.

Benzene

Benzene (C6H6) is a natural component of crude oil, petrol, diesel and other liquid fuels and is emitted when these fuels are combusted. Diesel exhaust emissions therefore contain benzene. After exposure to benzene, several factors determine whether harmful health effects will occur, as well as the type and severity of such health effects. These factors include the amount of benzene to which an individual is exposed and the length of time of the exposure. For example, brief exposure (5–10 minutes) to very high levels of benzene (14000 – 28000 µg/m3) can result in death (ATSDR, 2007). Lower levels (980 – 4200 µg/m3) can cause drowsiness, dizziness, rapid heart rate, headaches, tremors, confusion and unconsciousness. In most cases, people will stop feeling these effects when they are no longer exposed and begin to breathe fresh air. Inhalation of benzene for long periods may result in harmful effects in the tissues that form blood cells, especially the bone marrow. These effects can disrupt normal blood production and cause a decrease in important blood components. Excessive exposure to benzene can be harmful to the immune system, increasing the chance for infection. Both the International Agency for Cancer Research and the US-EPA have determined that benzene is carcinogenic to humans as long-term exposure to benzene can cause leukaemia, a cancer of the blood- forming organs.

2.3 Unit Processes

The unit processes for the 130 MW and 1 000 MW Zone 13: Inland Power Station are listed in Table 7.

Table 7: Unit processes at the Zone 13: Inland Power Station Name of the Unit Process Unit Process Function Batch or Continuous Gas Turbine/Reciprocating Engine: Unit 1 Electricity generation Continuous Gas Turbine/Reciprocating Engine: Unit 2 Electricity generation Continuous Gas Turbine/Reciprocating Engine: Unit 3 Electricity generation Continuous Gas Turbine/Reciprocating Engine: Unit 4 Electricity generation Continuous

3. TECHNICAL INFORMATION

3.1 Raw Materials Used

The proposed Zone 13: Inland Power Station initially uses diesel or HFO to generate 130 MW of electricity. Ultimately it will use LNG to generate 1 000 MW of electricity. The raw materials consumption rate for the proposed power plant, the production rate and the energy consumption are listed in Table 8 to Table 10. No by-products are produced.

Table 8: Raw material used at the proposed gas to power plant Maximum Material Type Units Phase consumption rate Diesel or HFO tbc Tonnes/month 130 MW LNG 14 160 Tonnes/month 1 000 MW Diesel tbc Tonnes/month 1 000 MW Fuel oil tbc Tonnes/month 1 000 MW

Table 9: Production rate Product Maximum production rate Units Phase Electricity 130 MW Initial Electricity 1 000 MW Ultimate

Table 10: Energy sources used Sulphur Ash content Maximum Units Phase Energy content of fuel of fuel (%) consumption source (%) rate Diesel/HFO 0.05% 0 tbc Tonnes/annum 130 MW Diesel/HFO 0.05% 0 tbc Tonnes/annum 1 000 MW

LNG 0.002% v/v H2S 0 1 681 920 Tonnes/annum 1 000 MW

3.2 Appliances and Abatement Equipment Control Technology

LNG is a clean fuel with very low SO2 and particulate emissions. No emission abatement will be installed for the control of these emissions.

The quantity of NOX produced is directly proportional to the temperature of the process. Depending on the technology choice, the generation process will be controlled to ensure the

NOX emission concentration complies with the MES for gas turbines or reciprocating gas engines.

Table 11: Appliances and abatement equipment and control technology Appliance Appliance Appliance Name Type/Description Function/Purpose No air pollution control and/or abatement technology are currently proposed

4. ATMOSPHERIC EMISSIONS

4.1 Point Source Parameters

The location of the stack and stack parameters are provided in Table 12.

Table 12: Location of stack and stack parameters Height of Height Point Diameter Actual gas Actual gas Actual gas Type of Point release above source at stack exit volumetric exit emission source Unit name above nearby coordinates tip/vent temperature flow velocity (continuous/ name ground building * exit (m) (K) (m³/hr) (m/s) batch) (m) (m) GT/RE 1 Latitude: Main GT/RE 2 -31.901°; 40 >6 7 833 1 773 830 40 Continuous stack GT/RE 3 Longitude: GT/RE 4 26.860° * Decimal degrees

4.2 Point Source Maximum Emission Rates (Normal Operating Conditions)

Power generation will be by means of a hybrid of gas turbines and gas engines. This range of possible technology options is assessed by assuming the ‘worst case’ scenario in terms of

emissions. This approach entails selecting the ‘worst case’ MES for SO2, NOX and PM for the respective technology (see MES in Table 5). The emission concentrations that are applied are listed in Table 13 with the respective emission rates, in bold text. The ‘worst case’ 3 emission scenario for PM, NOX and SO2 for diesel/HFO fuel combustion is 50 mg/Nm , 2 000 mg/Nm3 and 1 170 mg/Nm3, respectively).

Table 13: Power station stack emission concentrations and emission rates Substance Emission Emission rate Listed activity category concentration (tonnes/ (mg/Nm3) annum) Sulphur 400 6 216 1.4: Gas turbine - gas fired dioxide 1 170 18 180 1.5 Reciprocating engines - liquid fuels fired (SO2) 0 0 1.5 Reciprocating engines - gas fired Oxides of 50 777 1.4: Gas turbine - gas fired Nitrogen 2 000 31 078 1.5 Reciprocating engines - liquid fuels fired

(NOX) 400 6 216 1.5 Reciprocating engines - gas fired Particulate 10 155 1.4: Gas turbine - gas fired matter 50 777 1.5 Reciprocating engines - liquid fuels fired (PM) 50 777 1.5 Reciprocating engines - gas fired

4.3 Point Source Maximum Emission Rates (Start Up, Shut-Down, Upset and Maintenance Conditions)

Diesel will be used for plant start-up. Emission from start-up depend on the generation technology, the fuel consumption, and the frequency of events. Information is not available at this early stage, so the emissions have been excluded.

4.4 Fugitive Emissions

Storage of back-up fuel, not exceeding 8 000 m³ diesel and 8 000 m³ fuel oil, will be required at the power plant. These fuels will be stored in 4 storage tanks that vent to the atmosphere, each with a maximum capacity of 4 000 m3.

Fugitive emission will result from the handling and storage of these fuels. Both have a very low Reid Vapour pressure (< 1 kPa). According to the special arrangements for the fuel storage (DEA, 2010), products with a vapour pressure up to 14 kPa must be stored in a fixed roof tank which vents to the atmosphere. It is therefore assumed that the fuel storage yard will comprise four 4 000 m3 fixed roof storage tanks that meet the regulatory design requirements.

Emissions of VOCs from fixed roof tanks are from standing storage losses and working losses. Standing storage loss is the expulsion of vapour from tanks through vapour expansion and contraction, which is the result of changes in temperature and barometric pressure. This loss occurs without any change in liquid level in the tank. The loss from filling and emptying the tank is called working loss. Evaporation during filling operations is a result of an increase in the liquid level in the tank. As the liquid level increases, the pressure inside the tank exceeds the relief pressure and vapours are expelled from the tank. Evaporative loss during emptying occurs when air drawn into the tank during liquid removal becomes saturated with organic vapour and expands, thus exceeding the capacity of the vapour space.

Benzene emissions from each tank are estimated using the US EPA TANKS Emission Model (US EPA, 1999). An annual throughput of 19 919 m3 and 5 turnovers per annum are assumed per tank.

Individual tank emissions are summed to provide the total benzene emission for the tank yard of 0.58 kg per annum. The tank yard is treated as an area source.

Table 14: Tanks benzene emissions (kg/annum) Source number Storage name VOC Emission 1 Diesel tank 1 0.29 2 Diesel tank 2 0.29 3 Fuel oil tank 1 0 4 Fuel oil tank 2 0

4.5 Emergency Incidents

There have been no incidents as this is a new project.

5. IMPACT OF ENTERPRISE ON THE RECEIVING ENVIRONMENT

5.1 Baseline conditions

5.1.1 Introduction

5.1.2 Climate and meteorology

The Port Elizabeth region has a warm temperate climate, and the temperature range is not extreme, although high temperatures can occur during summer. Averages of daily minimum, maximum and mean temperatures for the period 1961 – 1990 are presented in Figure 5. High temperatures may be experienced during berg wind conditions when maximum temperatures my exceed 30°C.

Rain occurs throughout the year, brought about by convective summer rain and winter rain associated with the passage of frontal systems. The area receives an annual average rainfall of 624 mm. Monthly average rainfall data for Port Elizabeth Airport for the period 1961 – 1990 is presented in Figure 5.

30 90 (mm) rainfall monthly Average

C) ⁰ 20 60

10 30

Temperature( 5

0 0 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Mean maximum temperature Mean minimum temperature Average monthly rainfall

Figure 5:Average of daily minimum, maximum and mean temperatures (°C) and average monthly precipitation (mm) at Port Elizabeth Airport for the period 1961 – 1990

Prevailing wind tends to follow the coastline and the prevailing winds in the Port Elizabeth area are west-southwest and east-northeast. Wind roses are presented for Port Elizabeth Airport, Amsterdamplein, Motherwell and Saltworks in Figure 6. Wind roses simultaneously depict the frequency of occurrence of wind from the 16 cardinal wind directions and wind speed classes, for a single site. Wind direction is given as the direction from which the wind blows, i.e., southwesterly winds blow from the southwest. Wind speed is given in meters per second (m/s), and each arc represents a percentage frequency of occurrence (5% in this case).

The airport at Port Elizabeth is the most climatologically representative of the sites and is well exposed to the prevailing synoptic-scale winds, showing a high frequency of winds from the sector west to southwest (more than 50% of all winds). These are also the strongest winds. There is some occurrence of wind from the northeast and east at this site. The annual average wind speed here is 5.7 m/s.

The winds at Amsterdamplein, Motherwell and Saltworks also indicate the occurrence of reasonably strong west to southwesterly synoptic scale winds. At Amsterdamplein, winds are fairly, equally spread from the southwest, southeast, northwest, north and north- northeast, with an average wind speed of 4 m/s. At Motherwell, winds are predominantly from the northwest to southwest and east-southeast, with an average wind speed of 3.4 m/s. At Saltworks, winds are mainly from the west-northwest to southwest, north and east, also with an average wind speed of 3.4 m/s.

Poor atmospheric dispersion conditions typically occur with inversion conditions and calm or light winds. Greater surface cooling in winter is conducive to the formation of surface temperature inversions and a shallow mixing layer, particularly at night. Pollutants that are released into the inversion layer are typically trapped between the surface and the top of the inversion. Under light wind conditions, pollutants will tend to accumulate. It is under these conditions for May to July when the highest ground level concentrations of pollutants may be expected in the area.

Port Elizabeth Airport Amsterdamplein Total hours: 26116 Total hours: 13536 Avg. wind speed: 5.73 m/s Avg. wind speed: 4.04 m/s % Calm Winds: 3.05% % Calm Winds: 0%

Motherwell Saltworks Total hours: 14863 Total hours: 16887 Avg. wind speed: 3.40 m/s Avg. wind speed: 3.42 m/s % Calm Winds: 0.09% % Calm Winds: 0%

Figure 6: Annual wind roses for Port Elizabeth Airport, Amsterdamplein, Motherwell and Saltworks for 2009-2011. Arcs represent 5% frequency intervals.

5.1.3 Ambient Air Quality

The status of ambient air quality in the Coega SEZ is described here using data from the Saltworks monitoring site, and dispersion modelling for existing industries. Monitoring data provided accurate measurement at a single point which may not be representative of the entire area of interest. Dispersion modelling provides estimated concentrations over the area.

Ambient monitoring data for 2017 to 2019 at Saltworks is analysed for SO2, NO2, and PM10. A relatively coherent dataset was available for the Saltworks site for August 2017 to

December 2019. Monitored SO2 data show ambient levels for the monitoring period, with no exceedances of NAAQS. Monitored NO2 concentrations are elevated with higher concentrations observed in winter (i.e. June to August). Monitored PM10 concentrations are elevated year-round with no exceedances of NAAQS. An estimated background concentration of 10 µg/m3 is observed, increasing in late winter and early spring. This is consistent with inputs from regional biomass burning. An increasing annual trend can also be observed and is suggestive of additional air quality management needs in the area.

Figure 7: a) 1-hr and b) 24-hr average SO2 monitored concentrations

Figure 8: 1-hr average NO2 monitored concentrations

Figure 9: 24-hr average PM10 monitored concentrations

Table 15: Annual average monitored concentrations

Year SO2 NO2 PM10 NAAQS 50 µg/m3 NAAQS 40 µg/m3 NAAQS 40 µg/m3 2017* 3.3 8.5 14.8 2018 4.4 9.1 20.9 2019 1.6 10.7 26.6 * Limited dataset for August – December

Lethabo Air Quality Specialists have characterised emissions from industrial point sources, area sources, roads and shipping including and up to 5 km from the Coega SEZ (Pers. Comm. Chris Albertyn, June 2020). These emissions are used with dispersion modelling to illustrate ambient SO2, NO2 and PM10 concentrations throughout the Coega SEZ. In other words, dispersion modelling has been used to compliment the ambient monitoring data and to provide a spatially continuous picture of ambient concentrations throughout the SEZ. The relative location of industries relevant to this assessment are shown in Figure 10, in terms of distance and direction from the project.

Figure 10: Industrial Sources

For SO2 the annual, 24-hour and 1-hour modelled concentrations are shown by the isopleth maps in Figure 11. The limit value of the NAAQS is shown by the red isopleth in Figure 11, and the tolerance is shown by the yellow line. Ambient SO2 concentrations are generally relatively low compared with the NAAQS throughout the SEZ, but exceedances are shown to occur beyond the SEZ boundary to the west because of emissions from local sources. The low modelled SO2 concentrations in the SEZ agree with monitored concentrations at Saltworks. The maximum predicted annual average baseline concentration is 84.2 µg/m3 (Table 16).

For NO2 the annual and 1-hour modelled concentrations are shown by the isopleth maps in

Figure 12. The annual average ambient NO2 concentrations are relatively low throughout the SEZ and comply with the NAAQS. For 1-hour ambient concentrations, the limit value of the NAAQS is shown by the red isopleth in Figure 12, and the tolerance is shown by the yellow line. Ambient 1-hour NO2 concentrations are generally relatively low compared with the NAAQS throughout the SEZ, but exceedances are shown to occur beyond the SEZ boundary to the west and along the N2 to the east. The maximum predicted 1-hour baseline 3 concentration is 465 µg/m (Table 16). The generally low modelled NO2 concentrations in the SEZ agree with monitored concentrations at Saltworks.

Annual average and 24-hour PM10 concentrations are shown to be high over the central part of the SEZ where the NAAQS is exceeded (Figure 13). There are a number of sources of

PM10 in the SEZ with stacks and fugitive emissions resulting in the general area of exceedance. The NAAQS is also exceeded in places to the west of the SEZ because of local sources. While there are no exceedances of the NAAQS in the monitored data at Saltworks, the measured concentrations are relatively high. The highest annual average PM10 concentration is 159 µg/m3 (Table 16)

Table 16: Maximum predicted baseline ambient annual SO2, NO2 and PM10 concentrations in µg/m3 and the predicted 99th percentile concentrations for 24-hour and 1-hour, with the South African NAAQS

SO2 Description Annual 24-hour 1-hour Baseline 84.2 340 1 322 NAAQS 50 125 350

NO2 Baseline 30.2 465 NAAQS 40 200

PM10 Baseline 159 557 NAAQS 40 75

Figure 11: Modelled baseline annual average (top), 99th percentile of 24-hour 3 (middle) and of 1-hour (bottom) SO2 concentrations in the Coega SEZ in µg/m

Figure 12: Modelled baseline annual average (top) and 99th percentile of 1-hour 3 (bottom) NO2 concentrations in the Coega SEZ in µg/m

Figure 13: Modelled baseline annual average (top) and 99th percentile of 24-hour 3 (bottom) PM10 concentrations in the Coega SEZ in µg/m

5.2 Dispersion Modelling

5.2.1 Models used

A Level 3 air quality assessment must be conducted in situations where the purpose of the assessment requires a detailed understanding of the air quality impacts (time and space variation of the concentrations) and when it is important to account for causality effects, calms, non-linear plume trajectories, spatial variations in turbulent mixing, multiple source types and chemical transformations (DEA, 2014). A Level 3 assessment may be used in situations where there is a need to evaluate air quality consequences under a permitting or environmental assessment process for large industrial developments that have considerable social, economic and potential environmental consequences. Under these circumstances, the proposed CDC power project clearly demonstrates the need for a Level 3 assessment.

The CALPUFF suite of models are approved by the US EPA (http://www.src.com/calpuff/calpuff1.htm) and by the DEA for Level 3 assessments (DEA, 2014). It consists of a meteorological pre-processor, CALMET, the dispersion model, CALPUFF, and the post-processor, CALPOST. It is an appropriate air dispersion model for the purpose of this assessment as it is well suited to simulate dispersion from several sources. It also has capability to simulate dispersion in the atmosphere’s complex land-sea interface. More information about the model can be found in the User’s Guide for the CALPUFF Dispersion Model (US EPA, 1995).

The Air Pollution Model (TAPM) (Hurley, 2000; Hurley et al., 2001; Hurley et al., 2002) is used to model surface and upper air metrological data for the study domain. TAPM uses global gridded synoptic-scale meteorological data with observed surface data to simulate surface and upper air meteorology at given locations in the domain, taking the underlying topography and land cover into account. The global gridded data sets that are used are developed from surface and upper air data that are submitted routinely by all meteorological observing stations to the Global Telecommunication System of the World Meteorological Organisation. TAPM has been used successfully in Australia where it was developed (Hurley, 2000; Hurley et al., 2001; Hurley et al., 2002). It is considered to be an ideal tool for modelling applications where meteorological data does not adequately meet requirements for dispersion modelling. TAPM modelled output data is therefore used to augment the site-specific surface meteorological data for input to CALPUFF.

5.2.2 TAPM and CALPUFF parameterisation

TAPM is set-up in a nested configuration of three domains, centred on the Coega SEZ. The outer domain is 480 km by 480 km with a 24 km grid resolution, the middle domain is 240 km by 240 km with a 12 km grid resolution and the inner domain is 60 km by 60 km with a 3 km grid resolution (Figure 7.1). Three years (2017-2019) of hourly observed meteorological data from the SAWS station at Saltworks are used to ‘nudge’ the modelled meteorology towards the observations. The nesting configuration ensures that topographical effects on meteorology are captured and that meteorology is well resolved and characterised across the boundaries of the inner domain. Twenty seven vertical levels are modelled in each nest from 10 m to 5 000 m, with a finer resolution in the lowest 1 000 m.

The 3-dimensional TAPM meteorological output on the inner grid includes hourly wind speed and direction, temperature, relative humidity, total solar radiation, net radiation, sensible heat flux, evaporative heat flux, convective velocity scale, precipitation, mixing height, friction velocity and Obukhov length. The spatially and temporally resolved TAPM surface and upper air meteorological data is used as input to the CALPUFF meteorological pre- processor, CALMET.

A CALPUFF modelling domain will cover an area of 1 600 km2, where the domain extends 40 km (west-east) by 40 km (north-south) (Figure 14). It will consist of a uniformly spaced receptor grid with 0.25 km spacing, giving 25 600 grid cells (160 x 160 grid cells).

Figure 14: Proposed location of the modelling domains for TAPM and CALPUFF modelling

The topographical and land use for the respective modelling domains is obtained from the dataset accompanying the Commonwealth Scientific and Industrial Research Organisation (CSIRO) The Air Pollution Model (TAPM) modelling package (CSIRO, 2008). This dataset includes global terrain elevation and land use classification data on a longitude/latitude grid at 30-second grid spacing from the US Geological Survey, Earth Resources Observation Systems (EROS) Data Center.

The parameterisation of key variables that will apply in CALMET and CALPUFF are indicated in Table 17 and Table 18 respectively.

Table 17: Parameterisation of key variables for CALMET Parameter Model value 12 vertical cell face heights (m) 0, 20, 40, 80, 160, 320, 640, 1000, 1500, 2000, 2500, 3000, 4000 Coriolis parameter (per second) 0.0001 Empirical constants for mixing height Neutral, mechanical: 1.41 equation Convective: 0.15 Stable: 2400 Overwater, mechanical: 0.12 Minimum potential temperature lapse 0.001 rate (K/m) Depth of layer above convective mixing 200 height through which lapse rate is computed (m) Wind field model Diagnostic wind module Surface wind extrapolation Similarity theory Restrictions on extrapolation of surface No extrapolation as modelled upper air data data field is applied Radius of influence of terrain features 5 (km) Radius of influence of surface stations Not used as continuous surface data field is (km) applied

Table 18: Parameterisation of key variables for CALPUFF Parameter Model value

Chemical transformation Default NO2 conversion factor is applied Wind speed profile Urban Calm conditions Wind speed < 0.5 m/s Plume rise Transitional plume rise, stack tip downwash, and partial plume penetration is modelled Dispersion CALPUFF used in PUFF mode Dispersion option Pasquill-Gifford coefficients are used for rural and McElroy-Pooler coefficients are used for urban Terrain adjustment method Partial plume path adjustment

5.2.3 Model accuracy

Air quality models attempt to predict ambient concentrations based on “known” or measured parameters, such as wind speed, temperature profiles, solar radiation and emissions. There are however, variations in the parameters that are not measured, the so- called “unknown” parameters as well as unresolved details of atmospheric turbulent flow. Variations in these “unknown” parameters can result in deviations of the predicted concentrations of the same event, even though the “known” parameters are fixed.

There are also “reducible” uncertainties that result from inaccuracies in the model, errors in input values and errors in the measured concentrations. These might include poor quality or unrepresentative meteorological, geophysical and source emission data, errors in the measured concentrations that are used to compare with model predictions and inadequate model physics and formulation used to predict the concentrations. “Reducible” uncertainties can be controlled or minimised. This is done by using accurate input data, preparing the input files correctly, checking and re-checking for errors, correcting for odd model behaviour, ensuring that the errors in the measured data are minimised and applying appropriate model physics.

Models recommended in the DEA dispersion modelling guideline (DEA, 2014) have been evaluated using a range of modelling test kits (http://www.epa.gov./scram001). CALPUFF is one of the models that have been evaluated and it is therefore not mandatory to perform any modelling evaluations. Rather the accuracy of the modelling in this assessment is enhanced by every effort to minimise the “reducible” uncertainties in input data and model parameterisation.

5.2.4 Background Concentrations and other sources A background concentration refers to the portion of the ambient concentration of a pollutant due to sources, both natural and anthropogenic, other than the source being assessed.

A cumulative assessment of other sources of particulates (PM10 and PM2.5), NO2, SO2 and CO in the Coega EDZ and up to 5 km from the EDZ boundary is conducted using the CDC emission inventory provided by Lethabo Air Quality Specialists (pers. Comm. Chris Albertyn, June 2020). Included are industrial point sources, area sources, roads and shipping.

5.2.5 Sensitive Receptors According to the US EPA, sensitive receptors include, but are not limited to, hospitals, schools, day care facilities and old age homes. These are areas where the occupants are more susceptible to the adverse effects of exposure to toxic chemicals, pesticides, and other pollutants.

In this assessment, all neighbouring residential and commercial areas are treated as sensitive areas as they as expected to include sensitive areas as identified by the USEPA. The relative location of selected sensitive receptors that are relevant to this assessment are shown in Figure 15, in terms of distance and direction from the project.

Figure 15: Selected sensitive receptors

5.2.6 Assessment scenarios

To assess the potential impacts of the phased implementation of the Zone 13: Inland Power Plant and of the Coega 3 000 MW Integrated Power Project and its components on ambient air quality, it is necessary to assess different generation and emission scenarios.

Dispersion modelling is therefore undertaken for the following emission six scenarios:

i. Emissions from the 130 MW Zone 13: Inland Power Station (diesel/HFO fueled). ii. Emissions from the 130 MW Zone 13: Inland Power Station with emissions from existing sources and within a 5km radius of the Coega SEZ, i.e. the baseline conditions. iii. Emissions from the 1 000 MW Zone 13: Inland Power Station. iv. Emissions from the 1 000 MW Zone 13: Inland Power Station with emissions from existing sources and within a 5km radius of the Coega SEZ, i.e. the baseline conditions. v. Emissions for the Coega 3 000 MW Integrated Power Project, i.e. the three 1 000 MW power stations and the infrastructure project together, i.e. the cumulative effect of the entire project. vi. Emissions for the Coega 3 000 MW Integrated Power Project with emissions from existing sources and within a 5km radius of the Coega SEZ, the cumulative effect of the entire project with baseline conditions.

In addition, the potential cumulative effects on ambient air quality of other gas-to-power projects in the Coega SEZ are assessed qualitatively. These projects are i) the proposed Karpowership located in the Port of Ngqura and ii) the proposed Engie Gas-Fired Power Plant in Zone 13 of the Coega SEZ.

5.3 Dispersion Modelling Results

The dispersion modelling results are presented in the following sections for SO2, NO2, PM10, CO and benzene for the six emissions scenarios. First the maximum predicted ambient concentrations are presented in Section 5.3.1. An explanation of the model output is provided in Section 5.3.2, followed by the dispersion modelling results presented as isopleth maps.

5.3.1 Maximum predicted ambient concentrations and sensitive receptor concentrations

5.3.1.1 SO2

For SO2 for the 130 MW Inland Power Station in Zone 13 (Scenario 1) the maximum predicted annual average, 24-hour and 1-hour concentrations are very low and are well below the respective limit values of the NAAQS (Table 19). The maximum SO2

concentrations for the baseline (Scenario 2) however exceed the limit values of the NAAQS. The areas where the exceedances occur are shown in Figure 11. It is noteworthy that the addition by the 130 MW Zone 13 Power Station to existing ambient SO2 concentrations is very small. The exceedances occur because of emissions from existing sources.

For SO2 for the 1 000 MW Inland Power Station in Zone 13 (Scenario 1) the maximum predicted annual average, 24-hour and 1-hour concentrations are very low and are well below the respective limit values of the NAAQS (Table 19). The maximum SO2 concentrations for the baseline (Scenario 2) however exceed the limit values of the NAAQS. The areas where the exceedances occur are shown in Figure 11. It is noteworthy that the addition by the 1 000 MW Zone 13 Power Station to existing ambient SO2 concentrations is very small.

For SO2 for the 3 000 MW Coega Gas Project (Scenario 3) the maximum predicted annual average, 24-hour and 1-hour concentrations are very low and are well below the respective limit values of the NAAQS (Table 19). As noted above, the maximum SO2 concentrations for the baseline (Scenario 4) however exceed the limit values of the NAAQS, as mentioned above. However, it is noteworthy that the addition by the 3 000 MW Coega Gas Project to existing ambient SO2 concentrations is very small.

The predicted maximum annual average, 24-hour and 1-hour SO2 concentrations are well below the NAAQS at all of the 36 selected sensitive receptor points for the 130 MW power plant in Table 21 and the 1 000 MW power plant in Table 21.

3 Table 19: Maximum predicted ambient annual SO2 concentrations in µg/m and the predicted 99th percentile concentrations for 24-hour and 1-hour, with the South African NAAQS

SO2 Scenario Description Annual 24-hour 1-hour 1 130 MW liquid fuel Inland Power Station 1.0 15 27 2 130 MW liquid fuel Inland Power Station + 85.0 341 1 322 baseline 3 1 000 MW Inland Power Station 0.3 5.1 9.4 4 1 000 MW Inland Power Station + baseline 84.4 340 1 322 5 3 000 MW Coega Gas-to Power Project 1.2 15.5 29.2 6 3 000 MW Coega G2P Project + baseline 84.9 341 1 322 NAAQS 50 125 350

Table 20: Predicted maximum annual average, 24-hour and 1-hour SO2 concentrations in µg/m3 at the sensitive receptors for the two 130 MW scenarios Scenario 1 Scenario 2 RECEPTOR 1-hr 24-hr Annual 1-hr 24-hr Annual Addo Elephant National Park - 15.6 6.3 0.5 21.0 7.7 1.1 southern boundary Amsterdamhoek 2.9 2.5 0.1 28.3 11.8 1.7 Azalea Park 10.4 4.1 0.3 17.8 7.5 1.4 Bethelsdorp 6.6 3.8 0.2 16.5 6.8 0.8 Bluewater Bay - northern 2.6 2.3 0.1 31.8 10.1 2.3 boundary Brenton Island 11.4 7.0 0.4 29.9 11.6 2.3 Cerebos - Coega evaporation 3.3 4.1 0.2 35.4 14.0 3.4 area Cerebos - PVD Salt Pan 4.1 4.0 0.2 55.0 17.3 4.4 Cerebos - Sundays River 15.4 5.9 0.5 22.4 8.3 1.5 evaporation area Cerebos - Swartkops evaporation 15.1 6.6 0.5 34.2 14.4 2.6 area Coega Hotel Formal Dwelling 1 12.9 7.8 0.5 39.5 15.2 3.4 Coega Hotel Formal Dwelling 2 13.8 8.3 0.5 39.0 15.8 3.5 Coega Hotel Informal Dwelling 1 8.9 7.5 0.4 36.0 12.6 3.1 Coega Hotel Informal Dwelling 2 11.0 7.9 0.4 37.1 13.2 3.2 Colchester - southern boundary 12.6 4.4 0.4 17.2 6.3 1.1 Deal Party - northern boundary 2.3 1.8 0.1 20.8 8.3 1.0 Despatch 12.1 5.0 0.4 17.3 7.9 1.4 Harbour 2.5 3.1 0.1 32.1 10.6 2.5 Ibhayi - eastern boundary 4.1 2.9 0.1 18.5 7.1 1.0 Ibhayi - southeastern boundary 2.9 2.0 0.1 18.2 8.1 0.8 Jahleel Island 2.3 2.4 0.1 33.0 13.3 4.1 Markman Industrial - Central 4.9 4.8 0.2 102.4 44.6 9.6 Motherwell - Central 7.9 4.8 0.3 46.2 16.7 3.8 Motherwell - eastern boundary 9.5 5.8 0.3 81.3 43.9 7.1 Motherwell - northeastern 19.5 8.9 0.7 53.9 22.1 4.2 boundary Motherwell - southeastern 5.5 4.9 0.2 76.6 31.6 6.3 boundary Northern Farms 10.3 4.2 0.3 16.4 6.5 0.8 Sidwell 4.8 2.6 0.2 14.9 6.6 0.6 St Croix Island 9.5 4.4 0.4 28.1 9.7 2.1 St Georges Strand 2.7 2.6 0.1 38.5 16.6 3.4

Scenario 1 Scenario 2 RECEPTOR 1-hr 24-hr Annual 1-hr 24-hr Annual Sundays River- southern 12.6 4.9 0.4 19.1 7.1 1.2 boundary Tankatara Farm - central 18.4 7.9 0.6 24.6 10.4 1.5 Tankatara Farm - southern 19.1 9.1 0.7 33.1 13.3 2.1 boundary Transnet Property Dwelling 11.1 8.7 0.5 39.7 14.2 3.3 Uitenhage Farms 13.2 5.6 0.5 23.9 9.8 1.7 Wells Estate - northern boundary 3.7 3.9 0.2 49.5 16.0 3.8

3 Table 21: Predicted maximum annual average, 24-hour and 1-hour SO2 concentrations in µg/m at the sensitive receptors for the four 1 000 MW scenarios Scenario 3 Scenario 4 Scenario 5 Scenario 6 RECEPTOR 1-hr 24-hr Annual 1-hr 24-hr Annual 1-hr 24-hr Annual 1-hr 24-hr Annual Addo Elephant National Park - southern 5.3 2.2 0.2 14.4 5.2 0.8 11.3 4.9 0.5 18.2 7.6 1.1 boundary Amsterdamhoek 1.0 0.9 0.0 27.8 11.7 1.6 3.9 2.6 0.2 28.7 11.9 1.8 Azalea Park 3.6 1.4 0.1 14.8 5.7 1.2 10.5 4.1 0.5 17.3 7.6 1.6 Bethelsdorp 2.3 1.3 0.1 14.7 5.1 0.6 9.5 4.3 0.4 17.4 6.6 1.0 Bluewater Bay - 0.9 0.8 0.0 31.2 10.0 2.2 3.4 2.4 0.2 31.8 10.2 2.4 northern boundary Brenton Island 3.9 2.4 0.1 25.6 9.4 2.0 17.2 7.8 0.7 30.9 11.8 2.6 Cerebos - Coega 1.1 1.4 0.1 33.7 12.9 3.3 10.8 5.3 0.5 35.0 13.7 3.8 evaporation area Cerebos - PVD Salt 1.4 1.4 0.1 54.4 17.2 4.3 10.4 6.0 0.6 55.8 18.3 4.8 Pan Cerebos - Sundays 5.3 2.0 0.2 16.3 5.9 1.2 11.9 4.6 0.5 19.3 6.9 1.5 River evaporation area Cerebos - Swartkops 5.2 2.3 0.2 31.8 12.1 2.2 12.8 5.7 0.7 34.5 13.5 2.7 evaporation area Coega Hotel Formal 4.4 2.7 0.2 35.4 12.7 3.1 13.3 6.7 0.6 37.7 14.2 3.6 Dwelling 1 Coega Hotel Formal 4.7 2.8 0.2 35.5 13.2 3.1 13.0 6.7 0.6 37.5 14.1 3.6 Dwelling 2 Coega Hotel Informal 3.0 2.6 0.1 32.2 10.3 2.8 11.9 6.4 0.6 34.5 12.5 3.3 Dwelling 1 Coega Hotel Informal 3.8 2.7 0.2 33.2 11.2 2.9 12.9 6.8 0.6 35.4 12.2 3.3 Dwelling 2 Colchester - southern 4.3 1.5 0.2 12.6 5.0 0.8 10.1 3.5 0.5 15.7 5.8 1.1 boundary Deal Party - northern 0.8 0.6 0.0 20.3 8.1 1.0 3.3 2.1 0.2 21.2 8.4 1.1 boundary Despatch 4.1 1.7 0.2 13.7 5.8 1.1 10.0 4.2 0.5 16.3 7.0 1.5 Harbour 0.9 1.1 0.1 31.1 9.2 2.4 3.9 3.8 0.2 32.7 10.7 2.6

Scenario 3 Scenario 4 Scenario 5 Scenario 6 RECEPTOR 1-hr 24-hr Annual 1-hr 24-hr Annual 1-hr 24-hr Annual 1-hr 24-hr Annual Ibhayi - eastern 1.4 1.0 0.1 17.3 5.8 0.9 5.7 2.8 0.3 18.9 7.0 1.1 boundary Ibhayi - southeastern 1.0 0.7 0.0 17.5 6.9 0.8 3.7 2.2 0.2 18.8 8.2 0.9 boundary Jahleel Island 0.8 0.8 0.0 32.7 12.8 4.0 3.0 1.7 0.2 33.3 13.2 4.2 Markman Industrial - 1.7 1.6 0.1 98.6 42.9 9.4 11.1 4.5 0.5 102.1 44.2 9.9 Central Motherwell - Central 2.7 1.7 0.1 45.6 14.7 3.6 12.2 4.3 0.6 46.6 16.3 4.1 Motherwell - eastern 3.3 2.0 0.1 80.4 43.3 6.9 12.4 5.5 0.6 81.7 43.3 7.4 boundary Motherwell - 6.7 3.1 0.2 52.0 19.5 3.8 15.2 6.9 0.8 53.5 21.4 4.3 northeastern boundary Motherwell - 1.9 1.7 0.1 75.2 31.6 6.1 11.8 4.4 0.5 77.0 34.3 6.5 southeastern boundary Northern Farms 3.5 1.5 0.1 11.9 4.5 0.6 10.0 4.3 0.4 15.3 6.4 0.9 Sidwell 1.6 0.9 0.1 12.5 5.4 0.5 6.9 3.9 0.3 16.1 6.9 0.7 St Croix Island 3.2 1.5 0.1 24.9 8.6 1.9 10.0 4.4 0.5 27.1 9.4 2.3 St Georges Strand 0.9 0.9 0.1 37.7 16.1 3.3 3.8 2.9 0.2 38.5 16.2 3.4 Sundays River- 4.3 1.7 0.2 14.8 5.5 0.9 10.6 4.1 0.5 17.8 7.0 1.3 southern boundary Tankatara Farm - 6.3 2.7 0.2 18.2 6.5 1.1 12.5 4.9 0.5 21.0 8.2 1.4 central Tankatara Farm - 6.5 3.1 0.2 27.7 9.5 1.6 12.9 5.8 0.5 29.8 11.0 1.9 southern boundary Transnet Property 3.8 3.0 0.2 36.4 11.9 3.0 11.5 6.7 0.6 37.8 12.6 3.4 Dwelling Uitenhage Farms 4.5 1.9 0.2 21.3 7.9 1.4 11.8 5.2 0.5 23.5 9.7 1.7 Wells Estate - northern 1.3 1.4 0.1 48.9 15.3 3.7 7.5 3.5 0.3 49.6 16.1 4.0 boundary

5.3.1.2 NO2

For NO2 for the 130 MW Inland Power Station in Zone 13 (Scenario 1) the maximum predicted annual average and 1-hour concentrations are very low and are well below the respective limit values of the NAAQS (Table 22). The maximum 1-hour NO2 concentrations for the baseline (Scenario 2) however exceed the limit values of the NAAQS. The areas where the exceedances occur are shown in Figure 12. It is noteworthy that the addition by the 130 MW Zone 13 Power Station to ambient NO2 concentrations is very small. The exceedances are therefor because of emissions from existing sources.

For NO2 for the 1 000 MW Inland Power Station in Zone 13 (Scenario 1) the maximum predicted annual average and 1-hour concentrations are very low and are well below the respective limit values of the NAAQS (Table 22). The maximum 1-hour NO2 concentrations for the baseline (Scenario 2) however exceed the limit values of the NAAQS. The areas where the exceedances occur are shown in Figure 12. It is noteworthy that the addition by the 1 000 MW Zone 13 Power Station to ambient NO2 concentrations is very small.

For NO2 for the 3 000 MW Coega Gas Project (Scenario 3) the maximum predicted annual average and 1-hour concentrations are very low and are well below the respective limit values of the NAAQS (Table 22). As noted above, the maximum 1-hour NO2 concentrations for the baseline (Scenario 4) however exceed the limit values of the NAAQS, as mentioned above. However, it is noteworthy that the addition by the 3 000 MW Coega Gas Project to ambient NO2 concentrations is very small.

The predicted maximum annual average and 1-hour NO2 concentrations are well below the NAAQS at all of the 36 selected sensitive receptor points the 130 MW power plant in Table 23 and the 1 000 MW power plant in Table 24 (Table 24).

3 Table 22: Maximum predicted ambient annual NO2 concentrations in µg/m and the predicted 99th percentile concentrations for 1-hour with the South African NAAQS Scenario Description Annual 1-hour 1 130 MW liquid fuel Inland Power Station 1.3 38 2 130 MW liquid fuel Inland Power Station + baseline 31.3 465 3 1 000 MW Inland Power Station 0.3 7.5 4 1 000 MW Inland Power Station + baseline 30.5 465 5 3 000 MW Coega Gas-to Power Project 1.5 23.4 6 3 000 MW Coega G2P Project + baseline 30.8 466 NAAQS 40 200

Table 23: Predicted maximum annual average and 1-hour NO2 concentrations in µg/m3 at the sensitive receptors for the two 130 MW scenarios Scenario 1 Scenario 2 RECEPTOR 1-hour Annual 1-hour Annual Addo Elephant National Park - southern boundary 21.3 0.7 25.2 1.4 Amsterdamhoek 3.9 0.2 21.3 1.8 Azalea Park 14.3 0.4 19.2 1.3 Bethelsdorp 9.0 0.3 15.7 0.8 Bluewater Bay - northern boundary 3.6 0.2 39.4 3.0 Brenton Island 15.6 0.6 36.4 2.8 Cerebos - Coega evaporation area 4.5 0.2 40.6 5.4 Cerebos - PVD Salt Pan 5.6 0.3 62.9 6.1 Cerebos - Sundays River evaporation area 21.0 0.7 29.4 2.7 Cerebos - Swartkops evaporation area 20.6 0.7 34.1 2.6 Coega Hotel Formal Dwelling 1 17.6 0.7 44.0 4.2 Coega Hotel Formal Dwelling 2 18.9 0.7 44.4 4.2 Coega Hotel Informal Dwelling 1 12.2 0.6 41.1 4.1 Coega Hotel Informal Dwelling 2 15.1 0.6 41.9 4.1 Colchester - southern boundary 17.2 0.6 25.8 1.5 Deal Party - northern boundary 3.1 0.1 48.1 5.4 Despatch 16.5 0.6 19.9 1.4 Harbour 3.4 0.2 32.5 3.2 Ibhayi - eastern boundary 5.5 0.2 17.2 1.4 Ibhayi - southeastern boundary 4.0 0.2 20.5 1.3 Jahleel Island 3.1 0.2 35.6 5.2 Markman Industrial - Central 6.7 0.3 80.3 9.4 Motherwell - Central 10.7 0.4 43.8 3.8 Motherwell - eastern boundary 13.0 0.5 73.3 5.7 Motherwell - northeastern boundary 26.7 0.9 55.7 5.0 Motherwell - southeastern boundary 7.6 0.3 70.7 5.5 Northern Farms 14.1 0.4 19.1 1.0 Sidwell 6.5 0.3 17.4 0.7 St Croix Island 13.0 0.5 30.0 2.6 St Georges Strand 3.6 0.2 39.6 3.9 Sundays River- southern boundary 17.2 0.6 59.8 4.5 Tankatara Farm - central 25.2 0.8 30.1 2.0 Tankatara Farm - southern boundary 26.1 0.9 37.2 2.8 Transnet Property Dwelling 15.1 0.7 44.8 4.1

Scenario 1 Scenario 2 RECEPTOR 1-hour Annual 1-hour Annual Uitenhage Farms 18.1 0.6 31.7 1.9 Wells Estate - northern boundary 5.0 0.2 62.3 10.2

Table 24: Predicted maximum annual average and 1-hour NO2 concentrations in µg/m3 at the sensitive receptors for the four 1 000 MW scenarios Scenario 3 Scenario 4 Scenario 5 Scenario 6 RECEPTOR 1-hour Annual 1-hour Annual 1-hour Annual 1-hour Annual Addo Elephant National Park - 4.3 0.1 13.5 0.9 9.1 0.4 16.9 1.1 southern boundary Amsterdamhoek 0.8 0.0 19.8 1.6 3.3 0.2 20.9 1.8 Azalea Park 2.9 0.1 13.3 0.9 8.4 0.4 15.1 1.3 Bethelsdorp 1.8 0.1 11.9 0.5 7.7 0.4 14.4 0.8 Bluewater Bay - 0.7 0.0 38.2 2.9 3.2 0.2 39.1 3.0 northern boundary Brenton Island 3.1 0.1 26.5 2.4 13.7 0.6 30.1 2.9 Cerebos - Coega 0.9 0.1 37.3 5.2 8.7 0.5 39.4 5.6 evaporation area Cerebos - PVD Salt 1.1 0.1 60.9 5.9 9.2 0.6 65.2 6.4 Pan Cerebos - Sundays River evaporation 4.2 0.2 19.9 2.1 9.5 0.4 22.2 2.4 area Cerebos - Swartkops 4.1 0.2 27.9 2.1 10.3 0.6 30.4 2.5 evaporation area Coega Hotel Formal 3.5 0.1 39.8 3.7 10.7 0.6 41.5 4.1 Dwelling 1 Coega Hotel Formal 3.8 0.2 39.5 3.6 10.6 0.6 41.6 4.0 Dwelling 2 Coega Hotel 2.4 0.1 36.1 3.6 9.7 0.5 38.2 4.0 Informal Dwelling 1 Coega Hotel 3.0 0.1 36.2 3.6 10.3 0.5 38.3 4.0 Informal Dwelling 2 Colchester - 3.4 0.1 19.0 1.1 8.1 0.4 21.0 1.4 southern boundary Deal Party - 0.6 0.0 47.4 5.3 2.9 0.1 48.0 5.4 northern boundary Despatch 3.3 0.1 12.4 1.0 8.0 0.5 14.4 1.3 Harbour 0.7 0.0 30.2 3.1 4.9 0.3 32.5 3.4 Ibhayi - eastern 1.1 0.0 14.9 1.2 4.6 0.2 16.5 1.4 boundary Ibhayi - 0.8 0.0 19.3 1.2 3.1 0.2 20.6 1.3 southeastern

Scenario 3 Scenario 4 Scenario 5 Scenario 6 RECEPTOR 1-hour Annual 1-hour Annual 1-hour Annual 1-hour Annual boundary

Jahleel Island 0.6 0.0 34.9 5.1 3.6 0.3 36.6 5.3 Markman Industrial 1.3 0.1 78.2 9.2 9.0 0.5 79.4 9.7 - Central Motherwell - Central 2.2 0.1 41.4 3.5 9.8 0.5 42.9 3.9 Motherwell - eastern 2.6 0.1 70.3 5.3 10.0 0.6 72.0 5.8 boundary Motherwell - northeastern 5.3 0.2 47.9 4.3 12.2 0.7 50.4 4.8 boundary Motherwell - southeastern 1.5 0.1 69.0 5.2 9.5 0.5 70.3 5.7 boundary Northern Farms 2.8 0.1 12.2 0.7 8.0 0.3 15.2 0.9 Sidwell 1.3 0.1 12.4 0.5 5.7 0.2 16.4 0.7 St Croix Island 2.6 0.1 25.4 2.2 8.1 0.5 27.4 2.6 St Georges Strand 0.7 0.0 38.7 3.7 3.8 0.2 40.4 3.9 Sundays River- 3.4 0.1 57.5 4.0 8.6 0.4 59.4 4.4 southern boundary Tankatara Farm - 5.0 0.2 18.0 1.3 10.1 0.4 20.5 1.6 central Tankatara Farm - 5.2 0.2 26.1 2.1 10.3 0.4 27.9 2.4 southern boundary Transnet Property 3.0 0.1 37.4 3.5 9.3 0.5 40.0 3.8 Dwelling Uitenhage Farms 3.6 0.1 25.3 1.4 9.5 0.4 27.1 1.7 Wells Estate - 1.0 0.1 60.9 10.0 6.3 0.4 62.0 10.3 northern boundary

5.3.1.3 PM10

For PM10 for the 130 MW Inland Power Station in Zone 13 (Scenario 1) the maximum predicted annual average and 1-hour concentrations are very low and are well below the

respective limit values of the NAAQS (Table 25). The maximum 24-hour NO2 concentrations for the baseline (Scenario 2) however exceed the limit values of the NAAQS. The areas where the exceedances occur are shown in Figure 13. It is noteworthy that the addition by

the 130 MW Zone 13 Power Station to existing ambient PM10 concentrations is very small.

The exceedances are attributed to existing sources of PM10.

For PM10 for the 1 000 MW Inland Power Station in Zone 13 (Scenario 3) the maximum predicted annual average and 1-hour concentrations are very low and are well below the

respective limit values of the NAAQS (Table 25). The maximum 24-hour NO2 concentrations for the baseline (Scenario 3) however exceed the limit values of the NAAQS. The areas

where the exceedances occur are shown in Figure 13. It is noteworthy that the addition by the 1 000 MW Zone 13 Power Station to existing ambient PM10 concentrations is very small.

For PM10 for the 3 000 MW Coega Gas Project (Scenario 3) the maximum predicted annual average and 24-hour concentrations are very low and are well below the respective limit values of the NAAQS (Table 25). As noted above, the maximum 24-hour PM10 concentrations for the baseline (Scenario 4) however exceed the limit values of the NAAQS, as mentioned above. However, it is noteworthy that the addition by the 3 000 MW Coega

Gas Project to existing ambient PM10 concentrations is very small.

For the baseline scenarios, exceedances of the 24-hour NAAQS for PM10 are predicted at the Cerebos PVD Saltpan receptor point. Otherwise the predicted maximum annual average and

24-hour PM10 concentrations are well below the NAAQS at all of the selected sensitive receptor points the 130 MW power plant in Table 26 and the 1 000 MW power plant in (Table 26 and Table 27).

3 Table 25: Maximum predicted ambient annual PM10 concentrations in µg/m and the predicted 99th percentile concentrations for 24-hour with the South African NAAQS Scenario Description Annual 24-hour 1 130 MW liquid fuel Inland Power Station 0.04 0.6 2 130 MW liquid fuel Inland Power Station + baseline 159 557 3 1 000 MW Inland Power Station 0.04 0.6 4 1 000 MW Inland Power Station + baseline 159 557 5 3 000 MW Coega Gas-to Power Project 0.3 1.9 5 3 000 MW Coega G2P Project + baseline 160 557 NAAQS 40 75

Table 26: Predicted maximum annual average and 24-hour PM10 concentrations in µg/m3 at the sensitive receptors for the two 130 MW scenarios Scenario 1 Scenario 2 RECEPTOR 24-hr Annual 24-hr Annual Addo Elephant National Park - southern 0.3 0 5.9 0.6 boundary Amsterdamhoek 0.1 0 4.7 0.7 Azalea Park 0.2 0 4 0.5 Bethelsdorp 0.2 0 2 0.2 Bluewater Bay - northern boundary 0.1 0 6.3 1.2 Brenton Island 0.3 0 8.7 1.4 Cerebos - Coega evaporation area 0.2 0 16.9 4.3 Cerebos - PVD Salt Pan 0.2 0 116.2 15

Scenario 1 Scenario 2 RECEPTOR 24-hr Annual 24-hr Annual Cerebos - Sundays River evaporation area 0.3 0 13.7 1.4 Cerebos - Swartkops evaporation area 0.3 0 9 1.2 Coega Hotel Formal Dwelling 1 0.3 0 27.5 5.7 Coega Hotel Formal Dwelling 2 0.4 0 27.9 5.5 Coega Hotel Informal Dwelling 1 0.3 0 26.4 6.4 Coega Hotel Informal Dwelling 2 0.3 0 27.7 6 Colchester - southern boundary 0.2 0 4.8 0.5 Deal Party - northern boundary 0.1 0 4.5 0.6 Despatch 0.2 0 3.6 0.5 Harbour 0.1 0 11.2 2.2 Ibhayi - eastern boundary 0.1 0 3.4 0.7 Ibhayi - southeastern boundary 0.1 0 4.3 0.4 Jahleel Island 0.1 0 13.1 2.6 Markman Industrial - Central 0.2 0 12.1 2.4 Motherwell - Central 0.2 0 10.1 2 Motherwell - eastern boundary 0.3 0 20.7 3 Motherwell - northeastern boundary 0.4 0 17.7 3.1 Motherwell - southeastern boundary 0.2 0 10.6 2 Northern Farms 0.2 0 4.1 0.5 Sidwell 0.1 0 2.9 0.2 St Croix Island 0.2 0 8.1 1.4 St Georges Strand 0.1 0 7.5 1.4 Sundays River- southern boundary 0.2 0 5.8 0.8 Tankatara Farm - central 0.3 0 7.8 1.1 Tankatara Farm - southern boundary 0.4 0 18.6 2.3 Transnet Property Dwelling 0.4 0 39.7 7.5 Uitenhage Farms 0.2 0 5.7 0.8 Wells Estate - northern boundary 0.2 0 9.2 1.9

Table 27: Predicted maximum annual average and 24-hour PM10 concentrations in µg/m3 at the sensitive receptors for the four 1 000 MW scenarios Scenario 3 Scenario 4 Scenario 5 Scenario 6 RECEPTOR 24-hr Annual 24-hr Annual 24-hr Annual 24-hr Annual Addo Elephant National Park - 0.3 0.0 5.9 0.6 0.6 0.1 6.0 0.6 southern boundary Amsterdamhoek 0.1 0.0 4.7 0.7 0.3 0.0 4.7 0.7 Azalea Park 0.2 0.0 4.0 0.5 0.5 0.1 4.2 0.6 Bethelsdorp 0.2 0.0 2.0 0.2 0.5 0.1 2.2 0.3 Bluewater Bay - northern 0.1 0.0 6.3 1.2 0.3 0.0 6.3 1.2 boundary Brenton Island 0.3 0.0 8.7 1.4 1.0 0.1 8.8 1.4 Cerebos - Coega 0.2 0.0 16.9 4.3 0.7 0.1 16.9 4.3 evaporation area Cerebos - PVD 0.2 0.0 116.2 15.0 0.8 0.1 116.2 15.1 Salt Pan Cerebos - Sundays River 0.3 0.0 13.7 1.4 0.6 0.1 13.7 1.5 evaporation area Cerebos - Swartkops 0.3 0.0 9.0 1.2 0.7 0.1 9.0 1.3 evaporation area Coega Hotel Formal Dwelling 0.3 0.0 27.5 5.7 0.8 0.1 27.5 5.7 1 Coega Hotel Formal Dwelling 0.4 0.0 27.9 5.5 0.8 0.1 27.9 5.6 2 Coega Hotel Informal 0.3 0.0 26.4 6.4 0.8 0.1 26.4 6.4 Dwelling 1 Coega Hotel Informal 0.3 0.0 27.7 6.0 0.9 0.1 27.7 6.1 Dwelling 2 Colchester - southern 0.2 0.0 4.8 0.5 0.4 0.1 4.9 0.6 boundary Deal Party - northern 0.1 0.0 4.5 0.6 0.3 0.0 4.6 0.6 boundary Despatch 0.2 0.0 3.6 0.5 0.5 0.1 3.8 0.6 Harbour 0.1 0.0 11.2 2.2 0.5 0.0 11.2 2.2 Ibhayi - eastern 0.1 0.0 3.4 0.7 0.4 0.0 3.6 0.7 boundary Ibhayi - 0.1 0.0 4.3 0.4 0.3 0.0 4.3 0.5

Scenario 3 Scenario 4 Scenario 5 Scenario 6 RECEPTOR 24-hr Annual 24-hr Annual 24-hr Annual 24-hr Annual southeastern boundary Jahleel Island 0.1 0.0 13.1 2.6 0.2 0.0 13.1 2.6 Markman Industrial - 0.2 0.0 12.1 2.4 0.6 0.1 12.2 2.5 Central Motherwell - 0.2 0.0 10.1 2.0 0.5 0.1 10.1 2.0 Central Motherwell - eastern 0.3 0.0 20.7 3.0 0.7 0.1 21.2 3.0 boundary Motherwell - northeastern 0.4 0.0 17.7 3.1 0.9 0.1 17.8 3.2 boundary Motherwell - southeastern 0.2 0.0 10.6 2.0 0.6 0.1 10.7 2.0 boundary Northern Farms 0.2 0.0 4.1 0.5 0.5 0.0 4.3 0.5 Sidwell 0.1 0.0 2.9 0.2 0.5 0.0 3.1 0.3 St Croix Island 0.2 0.0 8.1 1.4 0.6 0.1 8.2 1.4 St Georges 0.1 0.0 7.5 1.4 0.4 0.0 7.5 1.4 Strand Sundays River- southern 0.2 0.0 5.8 0.8 0.5 0.1 6.0 0.9 boundary Tankatara Farm 0.3 0.0 7.8 1.1 0.6 0.1 8.2 1.1 - central Tankatara Farm - southern 0.4 0.0 18.6 2.3 0.7 0.1 18.7 2.3 boundary Transnet Property 0.4 0.0 39.7 7.5 0.8 0.1 39.7 7.5 Dwelling Uitenhage Farms 0.2 0.0 5.7 0.8 0.7 0.1 5.9 0.9 Wells Estate - northern 0.2 0.0 9.2 1.9 0.4 0.0 9.2 2.0 boundary

5.3.1.4 CO

For CO for the 130 MW Inland Power Station in Zone 13 (Scenario 1) the maximum predicted 8-hour and 1-hour concentrations are very low and are well below the respective limit values of the NAAQS (Table 28). It is noteworthy that the addition by the 130 MW Zone 13 Power Station to existing ambient CO concentrations is very small.

For CO for the 1 000 MW Inland Power Station in Zone 13 (Scenario 1) the maximum predicted 8-hour and 1-hour concentrations are very low and are well below the respective limit values of the NAAQS (Table 28). It is noteworthy that the addition by the 1 000 MW Zone 13 Power Station to existing ambient CO concentrations is very small.

For CO for the 3 000 MW Coega Gas Project (Scenario 3) the maximum predicted 8-hour and 1-hour concentrations are very low and are well below the respective limit values of the NAAQS (Table 28). It is noteworthy that the addition by the 3 000 MW Coega Gas Project to existing ambient CO concentrations is very small.

The predicted maximum 8hour and 1-hour CO concentrations are well below the NAAQS at all of the 36 selected sensitive receptor points the 130 MW power plant in Table 29 and the 1 000 MW power plant in Table 30.

Table 28: Maximum predicted ambient 8-hour and 1-hour CO concentrations in µg/m3 with the South African NAAQS Scenario Description 8-hour 1-hour 1 130 MW liquid fuel Inland Power Station 6.9 7.8 2 130 MW liquid fuel Inland Power Station + baseline 425 885 3 1 000 MW Inland Power Station 5.4 6.2 4 1 000 MW Inland Power Station + baseline 425 885 5 3 000 MW Coega Gas-to Power Project 839 1 570 6 3 000 MW Coega G2P Project + baseline 839 1 570 NAAQS 10 000 30 000

Table 29: Predicted maximum 8-hour and 1-hour CO concentrations in µg/m3 at the sensitive receptors for the two 130 MW scenarios RECEPTOR Scenario 1 Scenario 2 1-hr 8-hr 1-hr 8-hr Addo Elephant National Park - southern boundary 4.5 3.1 14.9 9.5 Amsterdamhoek 0.8 0.8 22.8 13.9 Azalea Park 3.0 2.1 14.3 8.8 Bethelsdorp 1.9 1.3 15.9 8.0 Bluewater Bay - northern boundary 0.7 0.9 31.0 18.4 Brenton Island 3.3 2.5 24.4 18.5 Cerebos - Coega evaporation area 0.9 1.5 33.6 18.7 Cerebos - PVD Salt Pan 1.2 1.5 31.1 17.3 Cerebos - Sundays River evaporation area 4.4 3.2 16.8 10.9 Cerebos - Swartkops evaporation area 4.3 2.9 30.2 18.0

RECEPTOR Scenario 1 Scenario 2 1-hr 8-hr 1-hr 8-hr Coega Hotel Formal Dwelling 1 3.7 3.8 65.9 30.7 Coega Hotel Formal Dwelling 2 4.0 3.9 66.8 33.1 Coega Hotel Informal Dwelling 1 2.5 3.0 51.6 26.6 Coega Hotel Informal Dwelling 2 3.2 3.3 55.8 26.1 Colchester - southern boundary 3.6 2.2 16.9 11.8 Deal Party - northern boundary 0.7 0.6 45.2 26.5 Despatch 3.5 2.2 14.7 8.3 Harbour 0.7 1.1 29.5 19.4 Ibhayi - eastern boundary 1.2 1.1 11.7 7.1 Ibhayi - southeastern boundary 0.8 0.7 17.2 11.1 Jahleel Island 0.7 0.9 28.1 18.6 Markman Industrial - Central 1.4 1.6 31.0 19.1 Motherwell - Central 2.2 2.1 25.8 14.8 Motherwell - eastern boundary 2.7 2.5 33.0 20.0 Motherwell - northeastern boundary 5.6 4.3 48.9 31.5 Motherwell - southeastern boundary 1.6 1.9 21.3 12.3 Northern Farms 3.0 2.0 13.0 8.9 Sidwell 1.4 1.2 11.7 7.0 St Croix Island 2.7 2.3 22.4 15.5 St Georges Strand 0.8 0.9 22.6 14.1 Sundays River- southern boundary 3.6 2.3 49.7 32.9 Tankatara Farm - central 5.3 3.8 17.2 10.2 Tankatara Farm - southern boundary 5.4 4.4 26.6 16.4 Transnet Property Dwelling 3.2 3.7 41.6 21.6 Uitenhage Farms 3.8 2.6 35.1 22.3 Wells Estate - northern boundary 1.1 1.3 57.4 35.9

Table 30: Predicted maximum 8-hour and 1-hour CO concentrations in µg/m3 at the sensitive receptors for the four 1 000 MW scenarios RECEPTOR Scenario 3 Scenario 4 Scenario 5 Scenario 6 1-hr 8-hr 1-hr 8-hr 1-hr 8-hr 1-hr 8-hr Addo Elephant National Park - 3.5 8.0 14.7 9.5 24.5 15.2 32.0 20.5 southern boundary Amsterdamhoek 0.7 3.6 22.8 13.9 18.6 10.5 32.9 18.5 Azalea Park 2.4 5.4 14.3 8.8 22.8 11.4 31.7 17.6 Bethelsdorp 1.5 5.5 15.7 8.0 13.8 7.7 27.0 15.0

RECEPTOR Scenario 3 Scenario 4 Scenario 5 Scenario 6 1-hr 8-hr 1-hr 8-hr 1-hr 8-hr 1-hr 8-hr Bluewater Bay - 0.6 3.7 31.0 18.4 25.7 15.9 48.1 27.6 northern boundary Brenton Island 2.6 9.8 24.4 18.5 84.9 53.2 93.0 64.6 Cerebos - Coega 0.8 8.0 33.6 18.7 112.1 69.1 116.4 69.1 evaporation area Cerebos - PVD Salt 0.9 5.9 31.0 17.3 344.7 172.6 345.8 175.1 Pan Cerebos - Sundays River evaporation 3.5 8.2 16.6 10.8 31.0 19.3 39.6 23.1 area Cerebos - Swartkops 3.4 7.2 30.2 18.0 51.5 28.4 71.1 43.8 evaporation area Coega Hotel 2.9 13.5 65.9 30.7 71.1 46.3 87.4 53.6 Formal Dwelling 1 Coega Hotel 3.1 14.7 66.6 33.1 70.9 46.7 87.2 52.1 Formal Dwelling 2 Coega Hotel Informal Dwelling 2.0 13.2 51.6 26.6 75.1 44.1 80.0 49.9 1 Coega Hotel Informal Dwelling 2.5 13.5 55.6 26.1 72.0 46.0 79.0 50.5 2 Colchester - 2.8 6.7 16.9 11.8 26.1 14.8 37.3 23.2 southern boundary Deal Party - 0.5 2.8 45.2 26.5 17.8 11.1 57.9 33.6 northern boundary Despatch 2.7 5.0 14.7 8.3 21.9 11.5 32.3 18.3 Harbour 0.6 4.6 29.5 19.4 21.8 17.2 38.9 24.9 Ibhayi - eastern 0.9 4.0 11.5 7.1 14.1 8.3 24.0 13.9 boundary Ibhayi - southeastern 0.7 3.2 17.2 11.0 16.0 10.0 33.2 19.9 boundary Jahleel Island 0.5 3.3 28.1 18.6 32.4 29.0 48.9 31.7 Markman 1.1 7.8 31.0 19.1 64.3 36.2 76.3 44.3 Industrial - Central Motherwell - 1.8 6.6 25.8 14.8 59.8 30.1 69.3 37.2 Central Motherwell - 2.1 7.9 33.0 19.5 85.2 45.9 90.7 51.0 eastern boundary Motherwell - northeastern 4.4 10.7 48.8 31.5 81.9 51.0 110.6 75.8 boundary Motherwell - southeastern 1.3 7.4 21.3 12.0 63.3 32.4 69.8 37.6 boundary

RECEPTOR Scenario 3 Scenario 4 Scenario 5 Scenario 6 1-hr 8-hr 1-hr 8-hr 1-hr 8-hr 1-hr 8-hr Northern Farms 2.3 6.7 12.9 8.7 20.8 13.4 29.1 20.0 Sidwell 1.1 5.8 11.6 7.0 13.9 8.4 23.5 13.4 St Croix Island 2.1 8.0 22.3 15.5 97.1 57.6 115.0 68.2 St Georges Strand 0.6 4.3 22.6 14.1 28.1 16.7 41.4 25.4 Sundays River- 2.8 7.4 49.7 32.9 31.5 17.1 72.3 43.9 southern boundary Tankatara Farm - 4.2 10.3 16.8 10.1 34.9 25.9 41.4 30.8 central Tankatara Farm - 4.3 13.6 26.2 16.4 51.7 29.0 61.5 35.8 southern boundary Transnet Property 2.5 15.8 41.4 21.3 80.1 48.2 84.4 51.4 Dwelling Uitenhage Farms 3.0 6.9 35.1 22.3 36.0 25.5 64.1 40.6 Wells Estate - 0.8 5.3 57.4 35.9 34.7 19.1 76.3 40.8 northern boundary

5.3.1.5 Benzene

For benzene for the 130 MW Inland Power Station in Zone 13 (Scenario 1) the maximum annual concentration is very low and are well below the limit values of the NAAQS (Table 31). It is noteworthy that the addition by the 130 MW Zone 13 Power Station to existing ambient benzene concentrations is very small.

For benzene for the 1 000 MW Inland Power Station in Zone 13 (Scenario 1) the maximum annual concentration is very low and are well below the limit values of the NAAQS (Table 31). It is noteworthy that the addition by the 1 000 MW Zone 13 Power Station to existing ambient benzene concentrations is very small.

The predicted maximum annual average benzene concentration is less than 0.00001 µg/m3 at all on the 36 selected receptor points.

Table 31: Maximum predicted annual benzene concentrations in µg/m3 with the South African NAAQS Scenario Description Annual 1 130 MW liquid fuel Inland Power Station 0.0001 2 130 MW liquid fuel Inland Power Station + baseline 0.0001 3 1 000 MW Inland Power Station 0.0001 4 1 000 MW Inland Power Station + baseline 0.0001 5 3 000 MW Coega Gas-to Power Project 0.0002 6 3 000 MW Coega G2P Project + baseline 0.0002 NAAQS 5

5.3.2 Isopleth maps

Maps of predicted ambient SO2, NO2, PM10 and CO concentrations for the four scenarios are presented in the following sections. The predicted concentrations are shown as isopleths, lines of equal concentration, in µg/m3 for the respective NAAQS averaging periods. The following should be noted:

• Isopleths are depicted as white lines. • Where the predicted ambient concentrations exceed the Limit Value of the NAAQS, the Limit Value is shown as a red isopleth. • Where the frequency of exceedances is greater than the permitted tolerance, the tolerance is shown as a yellow line on the maps. • The tolerance allows 4 exceedances per annum of the 24-hour limit value, so a line showing 12 exceedances is depicted when necessary. • The tolerance allows 88 exceedances per annum of the 1-hour limit value, so a line showing 264 exceedances is depicted when necessary.

5.3.2.1 Sulphur dioxide (SO2)

The predicted ambient SO2 concentrations are shown and compared for the six scenarios in Figure 16 to Figure 18 (130 MW) and Figure 19 to Figure 21 (1 000 MW).

• For Scenario 1, the 130 MW liquid fuel Zone 13 Power Station the predicted

ambient SO2 concentrations are very low and well below the NAAQS for the annual, 24-hour and 1-hour averaging periods. • For Scenario 2, the 130 MW liquid fuel Zone 13 Power Station with the current

baseline, the predicted ambient SO2 concentrations are generally low and well below the NAAQS in the SEZ for the annual, 24-hour and 1-hour averaging periods. However, exceedances are predicted to occur in three small areas to the west of the SEZ. It is noteworthy that these exceedances occur because of the existing sources and are not attributed to the small addition by the power plant.

• For Scenario 3, the 1 000 MW Zone 13 Power Station, the predicted ambient SO2 concentrations are very low and well below the NAAQS for the annual, 24-hour and 1-hour averaging periods. • For Scenario 4, the 1 000 MW Zone 13 Power Station with the current baseline,

the predicted ambient SO2 concentrations are generally low and well below the NAAQS in the SEZ for the annual, 24-hour and 1-hour averaging periods. However, exceedances are predicted to occur in three small areas to the west of the SEZ. It is noteworthy that these exceedances occur because of the existing sources and are not attributed to the small addition by the power plant.

• For Scenario 4, the 3 000 MW Coega Gas-to-Power Project, the predicted

ambient SO2 concentrations are very low and well below the NAAQS for the annual, 24-hour and 1-hour averaging periods. • For Scenario 6, the 3 000 MW Coega Gas-to-Power Project with the current

3 Figure 16: Predicted annual average SO2 concentrations in µg/m for Scenario 1 the 130 MW Power Station (top) and Scenario 2 the 130 MW Power Station with baseline (bottom)

th 3 Figure 17: Predicted 99 percentile of the 24-hour SO2 concentrations in µg/m for Scenario 1 the 130 MW Power Station (top) and Scenario 2 the 130 MW Power Station with baseline (bottom)

th Figure 18: Predicted 99 percentile of the 1-hour SO2 concentrations in µg/m3 for Scenario 1 the 130 MW Power Station (top) and Scenario 2 the 130 MW Power Station with baseline (bottom)

3 Figure 19: Predicted annual average SO2 concentrations in µg/m for Scenario 3 the 1 000 MW Power Station (top left), Scenario 4 the 1 000 MW Power Station with baseline (top right), Scenario 5 the 3 000 MW Coega G2P Project (bottom left) and Scenario 6 the 3 000 MW Coega G2P Project and baseline (bottom right)

th 3 Figure 20: Predicted 99 percentile of the 24-hour SO2 concentrations in µg/m for Scenario 3 the 1 000 MW Power Station (top left), Scenario 4 the 1 000 MW Power Station with baseline (top right), Scenario 5 the 3 000 MW Coega G2P Project (bottom left) and Scenario 6 the 3 000 MW Coega G2P Project and baseline (bottom right) 60

th 3 Figure 21: Predicted 99 percentile of the 1-hour SO2 concentrations in µg/m for Scenario 3 the 1 000 MW Power Station (top left), Scenario 4 the 1 000 MW Power Station with baseline (top right), Scenario 5 the 3 000 MW Coega G2P Project (bottom left) and Scenario 6 the 3 000 MW Coega G2P Project and baseline (bottom right) 61

5.3.2.2 Nitrogen dioxide (NO2)

The predicted ambient NO2 concentrations are shown and compared for the six scenarios in Figure 22 and Figure 23 (130 MW) and Figure 24 and Figure 25 (1 000 MW).

• For Scenario 1, the 130 MW Zone 13 Power Station, the predicted ambient NO2 concentrations are very low and well below the NAAQS for the annual and 1-hour averaging periods. • For Scenario 2, the 130 MW Zone 13 Power Station with the current baseline, the

predicted annual ambient NO2 concentrations are generally low and below the NAAQS in the SEZ. Noteworthy is the extension of relatively high concentrations along the N2. For the 1-hour averaging periods exceedances on the NAAQS are predicted to occur in two small areas to the west of the SEZ and along the N2 to the east. It is noteworthy that these exceedances occur because of the existing sources and are not attributed to the small addition by the power plant.

• For Scenario 3, the 1 000 MW Zone 13 Power Station, the predicted ambient NO2 concentrations are very low and well below the NAAQS for the annual and 1-hour averaging periods. • For Scenario 4, the 1 000 MW Zone 13 Power Station with the current baseline, the

NO2 concentrations are very low and well below the NAAQS for the annual and 1-hour averaging periods. • For Scenario 6, the 3 000 MW Coega Gas-to-Power Project with the current baseline,

the predicted ambient NO2 concentrations are generally low and below the NAAQS in the SEZ for the annual averaging period. However, exceedances are predicted to occur in two small areas to the west of the SEZ and along the N2 to the east. It is noteworthy that these exceedances occur because of the existing sources and are not attributed to the small addition by the power plant.

3 Figure 22: Predicted annual average NO2 concentrations in µg/m for Scenario 1 the 130 MW Power Station (top) and Scenario 2 the 130 MW Power Station with baseline (bottom)

th Figure 23: Predicted 99 percentile of the 1-hour NO2 concentrations in µg/m3 for Scenario 1 the 130 MW Power Station (top) and Scenario 2 the 130 MW Power Station with baseline (bottom)

3 Figure 24: Predicted annual average NO2 concentrations in µg/m for Scenario 3 the 1 000 MW Power Station (top left), Scenario 4 the 1 000 MW Power Station with baseline (top right), Scenario 5 the 3 000 MW Coega G2P Project (bottom left) and Scenario 6 the 3 000 MW Coega G2P Project and baseline (bottom right)

th 3 Figure 25: Predicted 99 percentile of the 1-hour NO2 concentrations in µg/m for Scenario 3 the 1 000 MW Power Station (top left), Scenario 4 the 1 000 MW Power Station with baseline (top right), Scenario 5 the 3 000 MW Coega G2P Project (bottom left) and Scenario 6 the 3 000 MW Coega G2P Project and baseline (bottom right) 66

5.3.2.3 Particulates (PM10)

The predicted ambient PM10 concentrations are shown and compared for the six scenarios in Figure 26 and Figure 27 (130 MW) and Figure 28 and Figure 29 (1 000 MW).

• For Scenario 1, the 130 MW Zone 13 Power Station, the predicted ambient PM10 concentrations are very low and well below the NAAQS for the annual and 24-hour averaging periods. • For Scenario 2, the 130 MW Zone 13 Power Station with the current baseline, the

predicted annual ambient PM10 concentrations are relatively high and exceed the NAAQS over the central parts of the SEZ and just northwest of the SEZ. It is noteworthy that these exceedances occur because of the existing sources and are not attributed to the small addition by the power plant.

• For Scenario 3, the 1 000 MW Zone 13 Power Station, the predicted ambient PM10 concentrations are very low and well below the NAAQS for the annual and 24-hour averaging periods. • For Scenario 4, the 1 000 MW Zone 13 Power Station with the current baseline, the

PM10 concentrations are very low and well below the NAAQS for the annual and 24- hour averaging periods. • For Scenario 6, the 3 000 MW Coega Gas-to-Power Project with the current baseline,

the predicted ambient PM10 concentrations are relatively high and exceed the NAAQS over the central parts of the SEZ and just northwest of the SEZ. It is noteworthy that these exceedances occur because of the existing sources and are not attributed to the small addition by the power plant.

3 Figure 26: Predicted annual average PM10 concentrations in µg/m for Scenario 1 the 130 MW Power Station (top) and Scenario 2 the 130 MW Power Station with baseline (bottom)

th Figure 27: Predicted 99 percentile of the 24-hour PM10 concentrations in µg/m3 for Scenario 1 the 130 MW Power Station (top) and Scenario 2 the 130 MW Power Station with baseline (bottom)

3 Figure 28: Predicted annual average PM10 concentrations in µg/m for 1) for Scenario 3 the 1 000 MW Power Station (top left), Scenario 4 the 1 000 MW Power Station with baseline (top right), Scenario 5 the 3 000 MW Coega G2P Project (bottom left) and Scenario 6 the 3 000 MW Coega G2P Project and baseline (bottom right)

th 3 Figure 29: Predicted 99 percentile of the 24-hour PM10 concentrations in µg/m for Scenario 3 the 1 000 MW Power Station (top left), Scenario 4 the 1 000 MW Power Station with baseline (top right), Scenario 5 the 3 000 MW Coega G2P Project (bottom left) and Scenario 6 the 3 000 MW Coega G2P Project and baseline (bottom right) 71

5.3.2.4 Carbon monoxide (CO)

The predicted ambient CO concentrations are shown and compared for the six scenarios in Figure 30 and Figure 31 (130 MW) and Figure 32 and Figure 33 (1 000 MW).

• For Scenario 1, the 130 MW Zone 13 Power Station, the predicted ambient CO concentrations are very low and well below the NAAQS for the 8-hour and 1-hour averaging periods. • For Scenario 2, the 130 MW Zone 13 Power Station with the current baseline, the predicted 8-hour and 1-hour CO concentrations are low throughout the SEZ. It is noteworthy that the contribution by the power plant to the baseline is very small. • For Scenario 3, the 1 000 MW Zone 13 Power Station, the predicted ambient CO concentrations are very low and well below the NAAQS for the 8-hour and 1-hour averaging periods. • For Scenario 4, the 1 000 MW Zone 13 Power Station with the current baseline, the predicted 8-hour and 1-hour CO concentrations are low throughout the SEZ. It is noteworthy that the contribution by the power plant to the baseline is very small. • For Scenario 5, the 3 000 MW Coega Gas-to-Power Project, the predicted ambient CO concentrations are very low and well below the NAAQS for the 8-hour and 1-hour averaging periods. • For Scenario 6, the 3 000 MW Coega Gas-to-Power Project with the current baseline, the predicted 8-hour and 1-hour CO concentrations are low throughout the SEZ. It is noteworthy that the contribution by the power plant to the baseline is very small.

Figure 30: Predicted 8-hour CO concentrations in µg/m 3 for Scenario 1 the 130 MW Power Station (top) and Scenario 2 the 130 MW Power Station with baseline (bottom)

Figure 31: Predicted 1-hour CO concentrations in µg/m 3 for Scenario 1 the 130 MW Power Station (top) and Scenario 2 the 130 MW Power Station with baseline (bottom)

Figure 32: Predicted 8-hour CO concentrations in µg/m 3 for Scenario 3 the 1 000 MW Power Station (top left), Scenario 4 the 1 000 MW Power Station with baseline (top right), Scenario 5 the 3 000 MW Coega G2P Project (bottom left) and Scenario 6 the 3 000 MW Coega G2P Project and baseline (bottom right)

Figure 33: Predicted 1-hour CO concentrations in µg/m 3 for Scenario 3 the 1 000 MW Power Station (top left), Scenario 4 the 1 000 MW Power Station with baseline (top right), Scenario 5 the 3 000 MW Coega G2P Project (bottom left) and Scenario 6 the 3 000 MW Coega G2P Project and baseline (bottom right)

5.4 Impact Assessment

5.4.1 Impact Rating Methodology

The assessment of impacts is based on the professional judgement of specialists and according to the impact assessment methodology presented below.

The significance of an impact is defined as a combination of the consequence of the impact occurring and the probability that the impact will occur. The criteria that are used to determine impact consequences are presented in Table 32.

Table 32: Criteria used to determine the Consequence of the Impact Rating Definition of Rating Score A. Extent– the area over which the impact will be experienced None 0 Local Confined to project site of the Coega SEZ 1 Regional The NMBMM 2 (Inter) Nationally or beyond 3 national B. Intensity– the magnitude of the impact in relation to the sensitivity of the receiving environment None 0 Low Site-specific and wider natural and/or social functions and 1 processes are negligibly altered Medium Site-specific and wider natural and/or social functions and 2 processes continue albeit in a modified way High Site-specific and wider natural and/or social functions or 3 processes are severely altered C. Duration– the time frame for which the impact will be experienced None 0 Short-term Up to 2 years 1 Medium- 2 to 15 years 2 term Long-term More than 15 years 3

The combined score of these three criteria corresponds to a Consequence Rating (Table 33).

Table 33: Method used to determine the Consequence Score Combined Score 0 – 2 3 – 4 5 6 7 8 – 9 (A+B+C) Consequence Rating Not Very Low Medium High Very significant low high

Once the consequence has been derived, the probability of the probability of the impact occurring is considered using the probability classifications presented in Table 34.

Table 34: Probability Classification Improbable < 40% chance of occurring Possible 40% - 70% chance of occurring Probable > 70% - 90% chance of occurring Definite > 90% chance of occurring

The overall significance of impacts is determined by considering consequence and probability using the rating system prescribed in Table 35.

Table 35: Impact Significance Ratings Significance Rating Possible Impact Combinations Consequence Probability Insignificant Very Low & Improbable Very Low & Possible Very Low Very Low & Probable Very Low & Definite Low & Improbable Low & Possible Low Low & Probable Low & Definite Medium & Improbable Medium & Possible Medium Medium & Probable Medium & Definite High & Improbable High & Possible High High & Probable High & Definite Very High & Improbable Very High & Possible Very High Very High & Probable Very High & Definite

Finally, the status of the impacts are considered (positive or negative impact) and the confidence in the assigned impact significance rating (Table 36).

Table 36: Impact status and confidence classification Status of impact Indication whether the impact is adverse (negative) or + ve (positive – a ‘benefit’) beneficial (positive). – ve (negative – a ‘cost’) Confidence of assessment The degree of confidence in predictions based on available Low information, specialist judgment and/or specialist Medium knowledge. High

5.4.2 Summary of Impacts

Using the scoring system described above, the potential impact of emissions from the 130 MW and the 1 000 MW Zone 13 Power Plant on ambient air quality is assessed. Also assessed are the cumulative emissions of the four projects that make up the 3 000 MW Coega Gas-to-Power Project.

The cumulative effect of the 130 MW Zone 13 Power Plant and the 3 000 MW Coega Gas-to- Power Project on current ambient air quality is assessed.

The respective impact summary scores for the 130 MW and the 1 000 MW Power Plant and the 3 000 MW Coega Gas-to-Power Project are captured in Table 37.

The 130 MW Zone 13 Power Plant:

• For SO2, NO2 and PM10, the extent of the potential impact is small and limited to the SEZ. For CO and benzene the predicted concentrations are very low and the extent of any potential impact is regarded as irrelevant. • The predicted ambient concentrations resulting from the power plant emissions are very low and the intensity is rated as low for all pollutants. • Although the intensity is very low, any impact will endure for the life of the power plant. The duration is therefore long term. • The consequence of the potential impact is therefore very low for all pollutants. • As the intensity is very low, the probability of air quality impacts from the power station are improbable for all pollutants. • The significance rating is considered low for all pollutants. • Air pollutants may have negative health effects even at low concentration. The status of the impact is therefore negative. • The assessment is based on representative data and has been conducted by an experienced team. A high level of confidence is placed on the findings of the assessment.

The 1 000 MW Zone 13 Power Plant:

very low and the intensity is rated as very low for NO2 all pollutants. • Although the intensity is very low or irrelevant, any impact will endure for the life of the power plant. The duration is therefore long term. • The consequence of the potential impact is therefore very low for all pollutants. • As the intensity is very low, the probability of air quality impacts from the power station are improbable for all pollutants. • The significance rating is considered to be insignificant for all pollutants. • Air pollutants may have negative health effects even at low concentration. The status of the impact is therefore negative.

• The assessment is based on representative data and has been conducted by an experienced team. A high level of confidence is placed on the findings of the assessment.

The 3 000 MW Coega Gas-to-Power Project:

Cumulative effect of the 130 MW Zone 13 Power Plant:

• For SO2, NO2 and PM10, the extent of the potential impact is small and limited to the SEZ. For CO and benzene the predicted concentrations are very low and the extent of any potential impact is regarded as irrelevant. The cumulative effect in the SEZ will therefore be very small or negligible. • The predicted ambient concentrations resulting from the power plant emissions are very low and the intensity is rated as irrelevant for all pollutants. It is highly unlikely that they will contribute to exceedances of the ambient standards. The cumulative effect in the SEZ will be very small or negligible. • The assessment is based on representative data and has been conducted by an experienced team. A high level of confidence is placed on the findings of the assessment.

Cumulative effect of the 1 000 MW Zone 13 Power Plant:

• For SO2, NO2 and PM10, the extent of the potential impact is small and limited to the SEZ. For CO and benzene the predicted concentrations are very low and the extent of any potential impact is regarded as irrelevant. The cumulative effect in the SEZ will therefore be very small or negligible. • The predicted ambient concentrations resulting from the power plant emissions are

• The assessment is based on representative data and has been conducted by an experienced team. A high level of confidence is placed on the findings of the assessment.

Cumulative effect of the 3 000 MW Coega Gas-2-Power Project:

• For SO2, NO2 and PM10, the extent of the potential impact is small and limited to the SEZ. For CO and benzene the predicted concentrations are very low and the extent of any potential impact is regarded as irrelevant. The cumulative effect in the SEZ will therefore be very small or negligible. • The predicted ambient concentrations resulting from the three power plant emissions

are very low and the intensity is rated as low for NO2 and irrelevant for the other pollutants. It is highly unlikely that they will contribute to exceedances of the ambient standards. The cumulative effect in the SEZ will be very small or negligible. • The assessment is based on representative data and has been conducted by an experienced team. A high level of confidence is placed on the findings of the assessment.

Cumulative effect of the other proposed gas-to-power project in the Coega SEZ • The proposed Karpowership project in the port of Ngqura is predicted maximum

concentrations of SO2, NO2 and PM are very low relative to the NAAQS. In all cases the predicted maximum increase is over the Coega SEZ. The maximum predicted 3 3 3 concentrations are of 0.09 µg/m for SO2, 1.8 µg/m for NO2 and 0.4 µg/m for PM10 (uMoya-NILU, 2020). • The proposed Engie gas-fired power plant will result in very low ambient

concentrations of SO2, NO2 and PM relative to the NAAQS. In all cases the predicted maximum increase will occur over the Coega SEZ (uMoya-NILU, 2021).

• For SO2, NO2 and PM10, the extent of the potential impact of the other gas-to-power projects is small and limited to the SEZ. The contribution will not significantly increase the ambient concentrations and will not result in exceedances of the NAAQS. The cumulative effect in the SEZ will therefore be very small or negligible. • The predicted ambient concentrations resulting from the power plant emissions are

very low and the intensity is rated as low for NO2 and irrelevant for the other pollutants. It is highly unlikely that they will contribute to exceedances of the ambient standards. The cumulative effect of the gas-to-power projects will be very small or negligible. • The cumulative assessment of the other gas-to-power projects is based on their respective AIRs.

Table 37: Air quality Impact Assessment summary scores Description Pollutants Extent Intensity Duration Consequence Probability Significance Status Confidence Reversibility

SO2 1 0 3 Very low Improbable Insignificant -ve High Yes

NO2 1 1 3 Very low Improbable Insignificant -ve High Yes

130 MW Power Station PM10 1 0 3 Very low Improbable Insignificant -ve High Yes

CO 0 0 3 Very low Improbable Insignificant -ve High Yes Benzene 0 0 3 Very low Improbable Insignificant -ve High Yes

SO2 1 0 3 Very low Improbable Insignificant -ve High Yes

NO2 1 1 3 Very Low Improbable Insignificant -ve High Yes

1 000 MW Power Station PM10 1 0 3 Very low Improbable Insignificant -ve High Yes CO 0 0 3 Very low Improbable Insignificant -ve High Yes

Benzene 0 0 3 Very low Improbable Insignificant -ve High Yes

SO2 1 0 3 Very low Improbable Insignificant -ve High Yes

NO2 1 1 3 Very low Improbable Insignificant -ve High Yes

3 000 MW Coega G2P Project PM10 1 0 3 Very low Improbable Insignificant -ve High Yes CO 0 0 3 Very low Improbable Insignificant -ve High Yes Benzene 0 0 3 Very low Improbable Insignificant -ve High Yes

SO2 1 0 3 Very low Improbable Insignificant -ve High Yes

NO2 1 1 3 Very Low Improbable Insignificant -ve High Yes

Other gas-to-power projects PM10 1 0 3 Very low Improbable Insignificant -ve High Yes CO 0 0 3 Very low Improbable Insignificant -ve High Yes Benzene 0 0 3 Very low Improbable Insignificant -ve High Yes

5.5 Analysis of Emissions’ Impact on the Environment

This AIR has focused on potential human health impacts. An assessment of the atmospheric impact of the facility on the environment was therefore not undertaken as part of this AIR.

6. COMPLAINTS

Not relevant to this AIR as this is a proposed facility.

7. CURRENT OR PLANNED AIR QUALITY MANAGEMENT INTERVENTIONS

Air quality management interventions to reduce emissions are deemed to be unnecessary considering the low impact of the project on air quality.

Routine emission measurements and other air quality monitoring may be stipulated by the Licensing Authority in the Atmospheric Emission License (AEL).

8. COMPLIANCE AND ENFORCEMENT ACTIONS

Not relevant to this AIR as this is a proposed facility.

9. SUMMARY AND CONCLUSION

The proposed Coega 3000 MW Integrated Gas-to-Power Project will ultimately include the following components a Liquefied Natural Gas (LNG) terminal and three 1000 MW Gas to Power plants. Two power plants are proposed in Zone 10 (coastal) and one in Zone 13 (inland) of the SEZ. Power generation will be by means of a hybrid of Combined Cycle Gas Turbines (CCGT), Open Cycle Gas Turbines (OCGT), and Reciprocating Engines (RE). Each power plant will use LNG as the primary source of fuel, with diesel and fuel oil as back up fuels. The different generation technologies and fuels result in somewhat different emissions. The assessment uses worse case approach and the highest Minimum Emission Standards between gas turbines and reciprocating engines, and between gas and liquid fuels are applied. On-site storage of back up fuels will include two 4 000 m³ tanks for diesel or two 4 000 m³ tanks for fuel oil.

The proposed Zone 13: Inland Power Station will initially generate up to 130 MW using liquid fuels (diesel or HFO) and ultimately generating 1 000 MW using LNG with the on- site liquid fuel storage tanks. This assessment considers the initial 130 MW liquid fuel power station in Zone 13 and the proposed 1 000 MW LNG power stations in Zone 13. The requirements of the Atmospheric Impact Report (AIR) have been adhered to and the methodology followed the regulatory requirement for dispersion modelling studies.

Low-sulphur diesel and low-sulphur HFO are relatively clean fuels and emissions from the 130 MW power station are relatively low. The predicted ambient concentrations of

SO2, NO2, PM10, CO and benzene resulting from the power plant emissions are very low. The significance rating for air quality impacts is insignificant for all pollutants.

LNG is a clean fuel. The predicted ambient concentrations of SO2, NO2, PM10, CO and benzene resulting from the power plant emissions are therefore very low. The significance rating for air quality impacts is insignificant for all pollutants.

Ambient monitoring and dispersion modelling show that ambient concentrations of SO2 and NO2 in the Coega SEZ are generally low, but there are some areas where NO2 exceedances occur. PM10 concentrations are relatively high and exceedances of ambient standards were modelled from baseline emission data. The cumulative effect of the initial 130 MW and power plant and ultimately of the 1 000 MW power plant will be very small and are highly unlikely to contribute to exceedances of the ambient standards.

The predicted ambient concentrations resulting from emissions from the CDC project as a whole (three 1 000 MW power plants and the infrastructure project) are very low and the intensity is rated as low for NO2 and irrelevant for the other pollutants. It is highly unlikely that they will contribute to exceedances of the ambient standards. The cumulative effect of the CDC project be very small or negligible.

10. REFERENCES

ATSDR 1997. Agency for Toxic Substances and Disease Registry. Toxicological profiles on CD Rom, issue 97-2. ASDTR, (2007): Agency for Toxic Substances and Disease Registry, Online [Available]: http://www.atsdr.cdc.gov/phshome-c.html 19 May 2008. CCINFO, 1998 and 2000. The Canadian Centre for Occupational Health and Safety database. http://ccinfoweb.ccohs.ca visited on 21 July 2003. EPA Technology Transfer Network (EPA-TTN) 2004. United Air Toxics Website [Online] Available: http://www.epa.gov/ttn/atw/hlthef 6 April 2004. DEA (2009): National Ambient Air Quality Standards, Government Gazette, 32861, Vol. 1210, 24 December 2009. DEA (2010): Listed Activities and Associated Minimum Emission Standards identified in terms of Section 21 of the Air Quality Act, Act No. 39 of 2004, Government Gazette 33064, Notice No. 248 of 31 March 2010. DEA (2012): National Ambient Air Quality Standard for Particulate Matter of Aerodynamic Diameter less than 2.5 micrometers, Notice 486, 29 June 2012, Government Gazette, 35463. DEA (2013): Listed activities and associated Minimum Emission Standards identified in terms of Section 21 of the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004), Government Gazette Notice No. 893 of 22 November 2013.

DEA (2014): Code of Practice for Air Dispersion Modelling in Air Quality Management in South Africa, Government Notice R.533, Government Gazette, no. 37804, 11 July 2014. DEA (2016): Declaration of Greenhouse Gases as Priority Pollutants, Government Notice 6, Government Gazette, no. 39578, 8 January 2016. Hesterberg TW, Bunn WB, McClellan RO, Hamade AK, Long CM and Valberg PA. (2009).

Critical Review of the Human Data on Short-term Nitrogen Dioxide (NO2)

Exposures: Evidence for NO2 No-Effect Levels. Critical Reviews in Toxicology, 39(9): 743-81. Hurley, P. (2000): Verification of TAPM meteorological predictions in the Melbourne region for a winter and summer month. Australian Meteorological Magazine, 49, 97-107. Hurley, P.J., Blockley, A. and Rayner, K. (2001): Verification of a prognostic meteorological and air pollution model for year-long predictions in the Kwinana industrial region of Western Australia. Atmospheric Environment, 35(10), 1871- 1880. Hurley, P.J., Physick, W.L. and Ashok, K.L. (2002): The Air Pollution Model (TAPM) Version 2, Part 21: summary of some verification studies, CSIRO Atmospheric Research Technical Paper No. 57, 46 p. Lippmann, M., 1992. Environmental toxicants: human exposures and their health effects. Van Nostrand Reinhold, New York. ISBN 0-442-00549-0. South African Weather Service, (1998): Climate of South Africa, Climate Statistics up to 1984. uMoya-NILU (2020): Atmospheric Impact Report Atmospheric Impact Report for the proposed Karpowership Project at Ngqura (Coega) Port, Report No. uMN095- 2020, June 2020. uMoya-NILU (2021): Atmospheric Impact Report in support of the Proposed Engie 200MW Gas to Power Project in the Coega Special Economic Zone, Report No.: uMN016-21, February 2021. US EPA United States Environmental Protection Agency (1999): User guide to Storage Tank Emissions Calculation Software, Version 4.0, http://www.epa.gov/ttnchie1/software/tanks/index.html. WHO (1997). Environmental Health Criteria 188 Oxides of Nitrogen. Second edition. Available: http://www.inchem.org/documents/ehc/ehc/ehc188.htm (accessed August 2014). WHO (1999): Guidelines for Air Quality, World Health Organisation, http://www.who.int/peh/air/Airqualitygd.htm. WHO (2000): Air Quality Guidelines for Europe, 2nd Edition, World Health Organisation, ISBN 92 890 1358 3. WHO (2003): Health aspects of air pollution with particulate matter, ozone and nitrogen dioxide. Report on a WHO Working Group Bonn, Germany 13-15 January 2003, WHO Geneva. WHO (2005): WHO Air quality guidelines for particulate matter, ozone, nitrogen dioxide and sulphur dioxide, Global update 2005, Summary of risk assessment, WHO/SDE/PHE/OEH/06.02. WHO (2013). Review of evidence on health aspects of air pollution – REVIHAAP Project. Technical report. Available: http://www.euro.who.int/__data/assets/pdf_file/0004/193108/REVIHAAP-Final- technical-report-final-version.pdf. (accessed September 2014).

11. FORMAL DECLARATIONS

A declaration of the accuracy of the information contained in this Atmospheric Impact Report is included here. A declaration of the independence of the practitioners in the uMoya-NILU consultancy team that compiled this AIR is also included.

DECLARATION OF ACCURACY OF INFORMATION – APPLICANT

Name of Enterprise: uMoya-NILU Consulting (Pty) Ltd

Declaration of accuracy of information provided:

Atmospheric Impact Report in terms of Section 30 of the Act

I, Mark Zunckel [duly authorised], declare that the information provided in this atmospheric impact report is, to the best of my knowledge, in all respects factually true and correct. I am aware that the supply of false or misleading information to an air quality office is a criminal office in terms of section 51(1)(g) of this Act.

Signed at Durban on this 20th day of April 2021.

______SIGNATURE

Managing Director – uMoya-NILU Consulting CAPACITY OF SIGNATORY

DECLARATION OF INDEPENDENCE – PRACTITIONER

Name of Practitioner: Mark Zunckel

Name of Registered Body: South African Council for Natural Scientific Professionals

Professional Registration Number: 400449/04

Declaration of independence and accuracy of information provided:

Atmospheric Impact Report in terms of Section 30 of the Act

I, Mark Zunckel declare that I am independent of the applicant. I have the necessary expertise to conduct the assessment required for the report and will perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the applicant. I will disclose to the applicant and the air quality officer all material information in my possession that reasonably has or may have the potential of influencing any decision to be taken with respect to the application by the air quality officer. The information provided in the atmospheric impact report is, to the best of my knowledge, in all respects factually true and correct. I am aware that the supply of false or misleading information to an air quality office is a criminal office in terms of section 51(1)(g) of this Act.

Signed at Durban on this 20th day of April 2021.

______SIGNATURE

Managing Director – uMoya-NILU Consulting CAPACITY OF SIGNATORY

ADDENDUM TO THE ATMOSPHERIC IMPACT REPORT

In support of the Environmental Application for the proposed 200 MW Mulilo-Total Gas- Fired Power Plant, Zone 13, Coega Special Economic Zone, Eastern Cape

Report issued by: Report issued to: uMoya-NILU Consulting (Pty) Ltd Mulilo Renewable Project Developments P O Box 20622 (Pty) Ltd Durban North, 4016 PO Box 548 Howard Place South Africa Cape Town, 7450 South Africa

Report Details

Client: Mulilo Renewable Project Developments (Pty) Ltd Report title: Addendum to the Atmospheric Impact Report in support of the Environmental Application for the proposed 200 MW Mulilo- Total Gas-fired Power Plant, Zone 13, Coega Special Economic Zone, Eastern Cape Project: uMN498-20 Report number: uMN015-21 Version: Draft 11 February 2021 Prepared by: uMoya-NILU Consulting (Pty) Ltd, P O Box 20622, Durban North 4016, South Africa Authors: Mark Zunckel and Atham Raghunandan

This report has been produced for Mulilo Renewable Project Developments (Pty) Ltd, by uMoya-NILU Consulting (Pty) Ltd. The intellectual property contained in this report remains vested in uMoya-NILU Consulting (Pty) Ltd. No part of the report may be reproduced in any manner without written permission from uMoya-NILU Consulting (Pty) Ltd and Mulilo Renewable Project Developments (Pty) Ltd.

When used in a reference this document should be cited as follows: uMoya-NILU (2021): Addendum to the Atmospheric Impact Report in support of the Environmental Application for the proposed 200 MW Mulilo-Total Gas-fired Power Plant, Zone 13, Coega Special Economic Zone, Eastern Cape, Report No. uMN015, February 2021.

TABLE OF CONTENTS

TABLE OF CONTENTS ...... i LIST OF TABLES ...... ii LIST OF FIGURES ...... ii 1. INTRODUCTION ...... 1 1.1 Introduction ...... 1 1.2 Mulilo-Total project overview ...... 1 1.3 Enterprise details ...... 1 1.4 Location and extent of plant ...... 2 1.5 Emission control officer ...... 3 1.6 Atmospheric Emission License (AEL) and other authorisations ...... 3 2. NATURE OF THE PROCES ...... 4 2.1 Listed activities ...... 4 2.2 Process Description ...... 5 2.2.1 Liquefied natural gas (LNG) ...... 5 2.2.2 Power generation ...... 6 2.2.3 Fuel handling and storage ...... 6 2.3 Unit Processes...... 7 3. TECHNICAL INFORMATION ...... 9 3.1 Raw materials ...... 9 3.2 Appliances and abatement control technology ...... 9 4. ATMOSPHERIC EMISSIONS ...... 10 4.1 Point source parameters ...... 10 4.2 Point source maximum emission rates (normal operations) ...... 10 4.3 Point source maximum emission rates (upset conditions) ...... 11 4.4 Area Sources ...... 11 4.5 Fugitive emissions ...... 11 4.6 Emergency incidents ...... 11 5. IMPACT OF ENTERPRISE ON THE RECEIVING ENVIRONMENT ...... 11 5.1 Identification of Issues ...... 11 5.1.1 Construction and decommissioning ...... 12 5.1.2 Operations ...... 12 5.2 Impact Assessment ...... 15 5.1.3 Impact Rating Methodology ...... 15 5.1.4 Summary of Impacts ...... 17 5.3 Analysis of Emissions’ Impact on the Environment ...... 21 6. COMPLAINTS ...... 21 7. CURRENT OR PLANNED AIR QUALITY MANAGEMENT INTERVENTIONS ...... 21 8. COMPLIANCE AND ENFORCEMENT ACTIONS ...... 21 9. SUMMARY AND CONCLUSION ...... 21 10. REFERENCES...... 22 11. FORMAL DECLARATIONS ...... 23

LIST OF TABLES

Table 1: Enterprise details ...... 1 Table 2: Site information ...... 2 Table 3: Current authorisations related to air quality ...... 4 Table 4: Details of the Listed Activities according to GN 248 (DEA, 2010) and its revisions (DEA, 2013, 2019 and 2020) ...... 4 Table 5: Minimum Emission Standards for Listed Activity 1.5 according to GN 248 (DEA, 2010) and its revisions (DEA, 2013, 2019 and 2020) ...... 5 Table 6: Unit processes at the Mulilo-Total Power Plant ...... 8 Table 7: Raw material used at the proposed gas to power plant ...... 9 Table 8: Production rate ...... 9 Table 9: Energy sources used ...... 9 Table 10: Appliances and abatement equipment and control technology ...... 9 Table 11: Stack emission rates (t/a) ...... 10 Table 12: Total emissions in tons/year from the 1 000 MW Zone 13 Power Plant using LNG and the 200 MW Mulilo-Total Power Plant ...... 11

Table 13: NAAQS for pollutants for SO2, NO2 and PM10 ...... 13 3 Table 14: Maximum predicted ambient annual SO2 concentrations in µg/m and the predicted 99th percentile concentrations for 24-hours and 1-hour for the 1 000 MW plant, and the equivalent maximum concentration for the 200 MW Mulilo- Total Plant. The NAAQS are also shown...... 14 3 Table 15: Maximum predicted ambient annual NO2 concentrations in µg/m and the predicted 99th percentile concentrations for 1-hour for the 1 000 MW plant, and the equivalent maximum concentration for the 200 MW Mulilo-Total Plant. The NAAQS are also shown...... 14 3 Table 16: Maximum predicted ambient annual PM10 concentrations in µg/m and the predicted 99th percentile concentrations for 24-hours for the 1 000 MW plant, and the equivalent maximum concentration for the 200 MW Mulilo-Total Plant. The NAAQS are also shown...... 15 Table 17: Criteria used to determine the Consequence of the Impact ...... 16 Table 18: Method used to determine the Consequence Score ...... 16 Table 19: Probability Classification ...... 16 Table 20: Impact Significance Ratings ...... 17 Table 21: Impact status and confidence classification ...... 17 Table 22: Air quality Impact Assessment summary scores ...... 20

LIST OF FIGURES

Figure 1: Location of the Mulilo-Total Zone 13 Power Plant in the Coega SEZ (top) and relative to the Dadisa Power Station (bottom) ...... 3 Figure 2: A Spark Ignition scheme for gas engines (left), and a bank of engines connected in series (right) ...... 6

1. INTRODUCTION

1.1 Introduction

An Atmospheric Impact Report (AIR) was prepared in support of the application by the Coega Development Corporation (CDC) to construct and operate a 1 000 MW gas-fired power plant in Zone 13 of the Coega Special Economic Zone (SEZ) (uMoya-NILU, 2021a). Environmental Authorisation for the application is pending.

Mulilo Renewable Project Developments (Pty) Ltd and Total South Africa propose to utilise a portion of the 1 000 MW of the CDC application and build and operate a 200 MW gas-fired power plant on a portion of Zone 13, known as the Mulilo-Total Power Plant.

This addendum to the AIR for the proposed 1 000 MW Zone 13 Power Plant is specific to the proposed 200 MW Mulilo-Total Power Plant. It presents the relevant technical details and provides a comparative assessment.

A qualitative assessment was undertaken to assess the relative difference, if any, in the impact assessment for the proposed 1 000 MW Power Plant in Zone 13 of the Coega SEZ, and the proposed 200 MW Mulilo-Total Power Plant.

1.2 Mulilo-Total project overview

The proposed 200 MW Mulilo-Total Power Plant in Zone 13 will comprise eleven reciprocating engines (Wärtsilä 18V50SG or similar) and fueled by natural gas. Each unit will generate approximately 18.3 MW of electrical power, giving a total combined installed capacity of approximately 200 MW. The electricity will be generated at 15 kV, and then stepped up to 132 kV at the on-site switching station, then evacuated from site via transmission lines to the Dedisa substation.

The fuel will be delivered to the project site from the Port of Ngqura as Liquified Natural Gas (LNG) by road tankers. The LNG is to be stored in several vacuum horizontal pressurized tanks with an anticipated total storage capacity of up to 4 000 m3.

1.3 Enterprise details

The enterprise details for the proposed 200 MW Mulilo-Total Power Plant in Zone 13 is listed in Table 1.

Table 1: Enterprise details Entity Name: To be confirmed Trading as: To be confirmed

1 Type of Enterprise, e.g. To be confirmed Company/Close Corporation/Trust, etc.: Company Registration Number: To be confirmed Top Floor Golf Park Registered Address: 4 Raapenberg Rd, Mowbray 7700 Postal Address: PO Box 548, Howard Place 7450 Telephone Number (General): 021 685 3240 Fax Number (General): 086 635 6809 Company Website: www.mulilo.com Industry Type/Nature of Trade: Energy Land Use Zoning as per Town Special Economic Zone Planning Scheme: Land Use Rights if outside Town N/A Planning Scheme: Responsible Person: To be confirmed Emissions Control Officer: To be confirmed Telephone Number: 021 685 3240 Cell Phone Number: N/A Fax Number: 086 635 6809 Email Address: [email protected] After Hours Contact Details: To be confirmed

1.4 Location and extent of plant

The site information for the proposed 200 MW Mulilo-Total Power Plant in Zone 13 is listed in Table 2. The site location is shown in Figure 1.

Table 2: Site information Physical Address of the Licensed Premises: To be Confirmed A portion of Zone 13 in the Coega Description of Site: Special Economic Zone Property Registration Number (Surveyor-

General Code): Coordinates (latitude, longitude) of Latitude: 33°44.7 S Approximate Centre of Operations (Decimal Longitude: 25°40.9 E Degrees): Coordinates (UTM) of Approximate Centre Easting: 35H 377998.4 m E of Operations: Northing: 35H 6265268 m S Extent (ha): 5.7 Elevation Above Mean Sea Level (m): 66 Province: Eastern Cape

2 Nelson Mandela Bay Metropolitan District/Metropolitan Municipality: Municipality Local Municipality: N/A Designated Priority Area (if applicable): N/A

Figure 1: Location of the proposed 200 MW Mulilo-Total Power Plant in the Coega SEZ (top) and relative to the Dedisa Power Station (bottom)

1.5 Emission Control Officer

The General Manager of the proposed 200 MW Mulilo-Total Power Plant will act as the Emission Control Officer (ECO) until the position has been filled.

1.6 Atmospheric Emission License (AEL) and other authorisations

3 An Atmospheric Emission Licence (AEL) nor any other authorisations have been issued for the proposed 200 MW Mulilo-Total Power Plant (Table 3).

2. NATURE OF THE PROCESS

2.1 Listed activities

The proposed 200 MW Mulilo-Total Power Plant will be based on Gas Reciprocating Engines. The combustion of gaseous fuel for steam production or electricity is a Listed Activity. The definition of the Listed Activity is shown in Table 4. The MES for Sub-category 1.5 are listed in Table 5.

Up to 4 000 m3 of LNG will be stored on site. The Listed Activity for storage and handling of petroleum products (sub-category 2.4) applies to LNG (Table 4). Products with a true vapour pressure at a product storage temperature of 91 kPa must be stored in a pressure vessel, or type 4 storage tank which are designed as cryogenic pressure vessels.

Table 4: Details of the Listed Activities according to GN 248 (DEA, 2010) and its revisions (DEA, 2013, 2019 and 2020)

Category of Listed Sub-category of the Application Activity Listed Activity

Category 1: Combustion Sub-category 1.5: Liquid and gas fuel stationary Installations Reciprocating engines engines used for electricity Liquid and gas fuel generation. stationary engines used for All installations with design electricity generation capacity equal to or greater than 10 MW heat input per unit, based on the lower calorific value of the fuel used.

4 Category 2: Petroleum Sub-category 2.4: Storage Petroleum products storage tanks Industry, the production and handling of petroleum and product transfer facilities. of gaseous and liquid products All permanent immobile liquid fuels as well as storage tanks larger than 1 000 petrochemicals from cubic metres cumulative tankage crude oil, coal, gas or capacity at a site. biomass

Table 5: Minimum Emission Standards for Listed Activity 1.5 according to GN 248 (DEA, 2010) and its revisions (DEA, 2013, 2019 and 2020) Substance or mixture of substances Minimum Emission Standards (mg/Nm3) under normal conditions of Common name Chemical symbol 15% O2, 273 Kelvin and 101.3 kPa. 1.5: Reciprocating engines (gas fired) Particulate matter N/A 50 a Oxides of nitrogen NOX 400

Sulphur dioxide SO2 N/A a: expressed as NO2

2.2 Process Description

2.2.1 Liquefied natural gas (LNG)

Natural gas used for energy generation is primarily methane, with low concentrations of other hydrocarbons, water, carbon dioxide (CO2), nitrogen, oxygen and some sulphur compounds. Liquefied Natural Gas (LNG) is natural gas which has been cooled below its boiling point of minus 161 °C in a process known as liquefaction. The process of liquefaction also involves extracting most of the impurities in raw natural gas. The remaining natural gas is primarily methane with only small amounts of other hydrocarbons and consequently is widely considered a clean fossil fuel.

LNG is a very clean fuel. The quantity and nature of emissions from LNG combustion depend on the quality of the fuel, fuel consumption and the combustion device.

The combustion of LNG results in gaseous emissions of oxides of nitrogen (NO + NO2 = NOX), carbon monoxide (CO), and trace amounts of sulphur dioxide (SO2) and particulate matter (PM). Carbon dioxide is the main Greenhouse Gas resulting from LNG combustion.

NOX is produced from thermal fixation of atmospheric nitrogen in the combustion flame and from oxidation of nitrogen bound in the LNG. The quantity of NOx produced is directly proportional to the temperature of the flame. Trace amounts of SO2 is produced from the combustion of sulphur in the LNG. The non-combustible portion of the fuel remains as solid waste and is emitted as particulates.

5 2.2.2 Power generation

The proposed 200 MW Mulilo-Total Power Plant will comprise eleven reciprocating engines (Wärtsilä 18V50SG or similar) connected in series and fueled with natural gas. The Wärtsilä 18V50SG engine is a spark-ignited lean-burn gas engine that operates according to the Otto cycle.

Gas is mixed with air before the inlet valves, and the gas-air mixture is compressed during the compression phase. Gas is also fed into a small pre-chamber, where the gas mixture is rich compared to the gas in the cylinder. At the end of the compression phase, a spark plug ignites the gas-air mixture in the pre-chamber. The flames from the nozzle of the prechamber ignite the gas-air mixture in the whole cylinder. After the working phase, the exhaust gas valves open, and the cylinder is emptied of exhaust gases. The intake air is turbocharged and intercooled.

The purpose of the fuel gas system is to supply the engine with a constant gas feed of suitable quality, pressure, temperature, and cleanness. It also shuts off the gas supply if any problem arises and provides ventilation of trapped gas. Each engine is equipped with a gas regulating unit which controls the gas feed pressure to the engine depending on the engine load. The gas regulating unit performs a leakage test of the main shut-off valves after every engine stop or shut-down. There is a separate pressure control line for the gas delivered to the pre- chamber. A typical bank of engines at a power plant is shown in Figure 2.

Figure 2: A Spark Ignition scheme for gas engines (left), and a bank of engines connected in series (right)

2.2.3 Fuel handling and storage

The fuel will be brought to site as LNG from the Port of Ngqura in road tankers via Neptune Road and the N2. Delivery will be either with LNG ISO containers with an LNG net capacity of approximately 17 tons or LNG trailers with an LNG net capacity of up to 25 tons. An

6 average of 13 truck rotations per day will be required by the proposed 200 MW Mulilo-Total Power Plant to ensure sufficient LNG, with a maximum of 30 truck rotations.

The truck unloading station is anticipated to require three unloading bays to accommodate the quantities of fuel required. It will be used to fill the LNG storage tanks from the LNG road- tankers. An unloading bay comprises 2 connection lines, one for the liquid unloading, and one for the gas return into the truck. The connection to the truck will be made either by flexible hoses or rigid arms. Prior to disconnection, the liquid connection line will be emptied of LNG towards the storage tank/trailer with pressurized gas. A dry cryogenic coupling will be used to ensure a safe disconnection and connection with no loss or spillage of liquids.

Noteworthy points are:  Top filling decreases the tank pressure due to condensation of the gas by the cold in- coming liquid. The tank pressure is indicated via transmitters to the control system, enabling it to automatically control the top and bottom filling valves.  Boil-off gases generated by natural LNG evaporation occurring mainly due to ambient heat input will be routed to the LNG stream going to the vaporizers.  The LNG will be transferred from the storage tanks to the vaporizers for regasification via LNG send-out pumps.  An LNG pump-skid will be fitted to each LNG tank. There will be at least one pump in redundancy, depending on the tank configuration. The pump is a submerged variable speed centrifugal LNG pump. The export flowrate and pressure will be automatically controlled to match the fuel gas demand of the power plant.  The vaporisers transform the LNG sent out from the LNG storage tanks into GNG (Gaseous Natural Gas) which is then used by the reciprocating engines for power generation.  The vaporization can utilize Ambient Air Vaporizers (AAV) or Water Heated Vaporizers (WHV) depending on the site conditions and the relative sizing of each of these options. Depending on the selected option, an additional gas heating system (electrical) might be used to ensure a suitable gas temperature delivery to the fuel gas system of the power plant. The plant will be set up with twelve ambient air vaporizers in an 8 and 4 duty and standby configuration.

2.3 Unit Processes

The unit processes for the proposed 200 MW Mulilo-Total Power Plant are listed in Table 6.

7 Table 6: Unit processes at the proposed 200 MW Mulilo-Total Power Plant Name of the Unit Unit Process Function Batch or Continuous Process Gas Engines: Unit 1 - 11 Electricity generation Continuous LNG Storage: Tanks 1 - 4 Fuel storage Continuous Heater Gas heating Continuous

8 3. TECHNICAL INFORMATION

3.1 Raw materials

The proposed 200 MW Mulilo-Total Power Plant will use LNG to generate electricity. The raw material consumption rate at the proposed power plant, the production rate and energy consumption are listed in Table 7 to Table 9. No by-products are produced.

Table 7: Raw material used at the proposed 200 MW Mulilo-Total Power Plant Maximum Material Type Units consumption rate LNG To be confirmed m3/day Water To be confirmed m3/month Lubricating oil To be confirmed Tonnes/month tbc: to be confirmed

Table 8: Production rate Product Maximum production rate Units Electricity Up to 200 MW

Table 9: Energy sources used Energy Sulphur content Ash content of Consumption Units source of fuel (%) fuel (%) rate LNG 0.001% 0 To be confirmed m3/annum tbc: to be confirmed

3.2 Appliances and abatement control technology

LNG is a clean fuel with very low SO2 and particulate emissions. No emission abatement will be installed for the control of these emissions (Table 10).

The quantity of NOX produced is directly proportional to the temperature of the process. The generation process will be controlled to ensure the NOX emission concentration complies with the MES for reciprocating gas engines.

Table 10: Appliances and abatement equipment and control technology Appliance Appliance Appliance Name Type/Description Function/Purpose No air pollution control and/or abatement technology are currently proposed

4. ATMOSPHERIC EMISSIONS

4.1 Point source parameters

The proposed 200 MW Mulilo-Total Power Plant will generate a maximum of 200 MW using eleven reciprocating engines of approximately 18 MW each. They will be connected in series a generation hall. The proposed 200 MW Mulilo-Total Power Plant will have a dedicated stack for each of the eleven reciprocating engines, with a height between 15 m and 30 m and diameter of 1 m.

4.2 Point source maximum emission rates (normal operations)

Emission rates (t/a) are calculated using emission factors for the Wärtsilä 18V50SG engines for LNG under full load. The emission factors are 1.2 g/kWh for NOX and 0.064 g/kWh for PM (Sutkowski, 2011). The total annual emissions are shown in Table 11.

Table 11: Stack emission rates (t/a)

Source Type Source number Source ID SO2 NOX PM10 Point 1 Stk1 N/A 199 10.6 Point 2 Stk2 0.0 199 10.6 Point 3 Stk3 0.0 199 10.6 Point 4 Stk4 0.0 199 10.6 Point 5 Stk5 0.0 199 10.6 Point 6 Stk6 0.0 199 10.6 Point 7 Stk7 0.0 199 10.6 Point 8 Stk8 0.0 199 10.6 Point 9 Stk9 0.0 199 10.6 Point 10 Stk10 0.0 199 10.6 Point 11 Stk11 0.0 199 10.6

Total annual emissions for the proposed 1 000 MW Zone 13 Power Plant are compared with those for the proposed 200 MW Mulilo-Total Power Plant in Table 12. The emission rates for the proposed 1 000 MW plant are based on MES emission concentrations, while the emission rates for the proposed 200 MW Mulilo-Total Power Plant are calculated using engine specific emission factors.

It is noteworthy that the NOX emission for the proposed 200 MW Mulilo-Total Power Plant is 35% of the emission that was used to assess the proposed 1 000 MW plant (Table 12). The

PM10 emission is just 15% of the emission of the proposed 1 000 MW plant. For SO2 an emission of 6 216 t/a was used to assess the proposed 1 000 MW plant using LNG. This results from using the MES of 400 mg/Nm3. There is no sulphur in LNG so there is no emission factor for SO2 for LNG combustion for the Wärtsilä engines.

10 Table 12: Total emissions in tons/year from the proposed 1 000 MW Zone 13 Power Plant using LNG and the proposed 200 MW Mulilo-Total Power Plant using LNG 1 000 MW Zone 13 200 MW Mulilo-Total Percentage of 1 000 Substance Power Plant* Power Plant MW emission

SO2 6 216 0.0 N/A

PM10 777 117 15%

NOX 6 216 2 189 35%  uMoya-NILU (2021a)

4.3 Point source maximum emission rates (upset conditions)

LNG will be used for plant start-up. Emission from start-up depend on fuel consumption and the duration and frequency of start-up events.

4.4 Area Sources

An average 13 truck rotations per day will be required ensuring sufficient supply of LNG, with a maximum of 30 truck rotations. Truck exhaust emissions at the offloading facility may be regarded as an area source. With one truck rotation approximately hourly in a 12-hour working day, it will be a very small source of SO2, NOX, and particulates.

4.5 Fugitive emissions

Loading of LNG between the trucks and storage tanks is a potential source of fugitive emission, mostly of CH4. There are no potential fugitive sources of SO2, NOX and particulates.

4.6 Emergency incidents

There have been no incidents as this is a proposed project.

5. IMPACT OF ENTERPRISE ON THE RECEIVING ENVIRONMENT

5.1 Identification of Issues

Potential air quality issues resulting from the proposed 200 MW Mulilo-Total Power Plant may occur during construction and operations.

11 5.1.1 Construction and decommissioning

Construction work will entail clearing of vegetation, preparation of the building terrace, building of new infrastructure and heavy construction work with concrete, steel, piping, etc. Dust emissions during construction result mainly from earth moving activities (scraping, compacting, excavation, grading), movement of construction vehicles and back-fill operations. Dust emissions during decommissioning result from the demolition of structures, earth moving activities (scraping, compacting, excavation, grading), movement of construction vehicles and back-fill operations. All aspects of the construction inherently generate dust, but the movement of construction vehicles on paved and unpaved surfaces at the construction site are generally the largest source of dust. Construction vehicles will be in operation for the duration of the construction and decommissioning. Dust is also readily entrained from dry denuded areas by the wind.

The impact of dust is more of a nuisance nature and does not typically pose a health risk due to its typically coarse size. The impact of dust from the construction and decommissioning activities on air quality is expected to be relatively short lived, i.e. limited to the duration of the construction or decommissioning activities. The impacts are also expected to be localised and limited to the area immediately adjacent to the construction or decommissioning activities.

5.1.2 Operations

Emissions of NOX and particulates from operations will result from the combustion of LNG to generate electricity. These emissions will increase ambient NO2 and PM10 concentrations in the vicinity of the plant. Exposure to air pollutants in the ambient environment may present health risks depending on several factors, i.e. the pollutant, the concentration that an individual is exposed to, the duration of the exposure, and the sensitivity of the individual.

Emissions of SO2 will be negligible.

The health-based National Ambient Air Quality Standards (NAAQS) consists of a limit value and a permitted frequency of exceedance (

12 Table 13). The limit value is the fixed concentration level aimed at reducing the harmful effects of a pollutant. The permitted frequency of exceedance represents the tolerated exceedance of the limit value. Being health-based standards, compliance implies that air quality is acceptable and poses little or no risk to human health while exposure to ambient concentrations that exceed of the NAAQS implies that there is a risk to human health. The NAAQS for SO2, NO2 and PM10 are listed in

13 Table 13.

14 Table 13: NAAQS for pollutants for SO2, NO2 and PM10 Pollutant Averaging period Limit value (µg/m3) Tolerance

SO2 1 hour 350 88 24 hour 125 4 1 year 50 0

NO2 1 hour 200 88 1 year 40 0

PM10 24 hour 75 4 1 year 40 0

Dispersion modelling using the CALPUFF model was used to predict ambient concentrations of pollutants emitted from emissions of the proposed 1 000 MW Zone 13 Power Plant for different scenarios (uMoya-NILU, 2021a). Relevant to this annexure for the proposed 200 MW Mulilo-Total Power Plant are the scenarios assessing the proposed 1 000 MW plant only and the scenario assessing the proposed 1 000 MW plant with all other existing sources.

Specifically, the predicted maximum ambient SO2, NO2 and PM10 concentrations for these scenarios are relevant.

In comparing the predicted ambient concentrations resulting from the proposed 1 000 MW Zone 13 Power Plant with the proposed 200 MW Mulilo-Total Power Plant, the following points are relevant:

• The proposed location for the 200 MW Mulilo-Total Power Plant is on a portion of the proposed 1 000 MW Zone 13 Power Plant site. • The stack height for the proposed 200 MW Mulilo-Total Power Plant will be somewhat lower than the proposed 1 000 MW Power Plant. This may result in the maximum predicted ambient concentrations occurring somewhat closer to the 200 MW plant. • There is a linear relationship between emissions and ambient concentrations in dispersion modelling. In other words, an increase in emission of 10% will result in an increase in ambient concentrations of 10%. Similarly, a decrease of 10% in emissions will result in a decrease of 10% in the predicted ambient concentrations.

For SO2

The maximum predicted ambient SO2 concentrations for the two scenarios are presented in Table 14. For the proposed 1 000 MW Zone 13 Power Plant (Scenario 1) the maximum predicted annual average, 24-hour and 1-hour concentrations are very low and are well below the respective limit values of the NAAQS (

15 Table 13).

However, the maximum predicted SO2 concentrations for the baseline (Scenario 2) exceed the limit values of the NAAQS to the east of the Coega SEZ near the existing brickworks.

It must be noted that the addition to existing ambient SO2 concentrations by the proposed 1 000 MW Zone 13 Power Plant is very small. By comparison, the contribution of the proposed

200 MW Mulilo-Total Power Plant to existing ambient SO2 concentrations is negligible as there is no emission of SO2.

3 Table 14: Maximum predicted ambient annual SO2 concentrations in µg/m and the predicted 99th percentile concentrations for 24-hours and 1-hour for the proposed 1 000 MW plant, and the equivalent maximum concentration for the proposed 200 MW Mulilo-Total Power Plant. The NAAQS are also shown. Scenario Description Annual 24-hour 1-hour 1 1 000 MW Zone 13 Power Plant* 0.3 5.1 9.4 2 1 000 MW Zone 13 Power Plant + baseline* 84.4 340 1 322 3 200 MW Mulilo-Total Power Plant** 0.0 0.0 0.0 NAAQS 50 125 350  uMoya-NILU (2021a) ** 35% of the 1 000 MW contribution (Table 12)

For NO2

The maximum predicted NO2 concentrations for the two scenarios are presented in Table 15. For the proposed 1 000 MW Zone 13 Power Plant (Scenario 1) the maximum predicted annual average and 1-hour concentrations are very low and are well below the respective limit values of the NAAQS (Table 15). However, the maximum predicted 1-hour NO2 concentrations for the baseline (Scenario 2) exceed the limit values of the NAAQS to the east of the Coega SEZ near the existing brickworks and over the Markman industrial area.

It must be noted that the addition to existing ambient NO2 concentrations by the proposed 1 000 MW Zone 13 Power Plant is very small. The contribution of the proposed 200 MW

Mulilo-Total Power Plant to existing ambient NO2 concentrations is approximately 35% of the proposed 1 000 MW plant’s contribution (Table 12) and is relatively very small (Table 15).

3 Table 15: Maximum predicted ambient annual NO2 concentrations in µg/m and the predicted 99th percentile concentrations for 1-hour for the proposed 1 000 MW plant, and the equivalent maximum concentration for the proposed 200 MW Mulilo-Total Power Plant. The NAAQS are also shown. Scenario Description Annual 1-hour 1 1 000 MW Zone 13 Power Plant* 0.3 7.5

16 2 1 000 MW Zone 13 Power Plant + baseline* 30.5 465 3 200 MW Mulilo-Total Power Plant** 0.1 2.6 NAAQS 40 200  uMoya-NILU (2021a) ** 35% of the 1 000 MW contribution (Table 12)

For PM10

The maximum predicted PM10 concentrations for the two scenarios are presented in Table 16. For the proposed 1 000 MW Zone 13 Power Plant (Scenario 1) the maximum predicted annual average and 24-hour concentrations are very low and are well below the respective limit values of the NAAQS (

17 Table 13Table 15).

However, the maximum predicted annual average and 24-hour concentrations for the baseline (Scenario 2) exceed the limit values of the NAAQS to the east of the Coega SEZ near the existing brickworks, the Markman industrial area and over the central parts of the Coega SEZ.

It must be noted that the addition to existing ambient PM10 concentrations by the proposed 1 000 MW Zone 13 Power Plant is very small. The contribution of the proposed 200 MW

Mulilo-Total Power Plant to existing ambient PM10 concentrations will be approximately 15% of the proposed 1 000 MW plant’s contribution (Table 12) and is relatively very small (Table 16).

3 Table 16: Maximum predicted ambient annual PM10 concentrations in µg/m and the predicted 99th percentile concentrations for 24-hours for the proposed 1 000 MW plant, and the equivalent maximum concentration for the proposed 200 MW Mulilo-Total Power Plant. The NAAQS are also shown. Scenario Description Annual 24-hour 1 1 000 MW Zone 13 Power Plant* 0.04 0.6 2 1 000 MW Zone 13 Power Plant+ baseline* 159 557 3 200 MW Mulilo-Total Power Plant** 0.006 0.39 NAAQS 40 75  uMoya-NILU (2021a) ** 15% of the 1 000 MW contribution (Table 12)

5.2 Impact Assessment

5.1.3 Impact Rating Methodology

The assessment of impacts is based on the professional judgement of specialists and according to the impact assessment methodology presented below.

18 Table 17: Criteria used to determine the Consequence of the Impact Rating Definition of Rating Score A. Extent– the area over which the impact will be experienced None 0 Local Confined to project site of the Coega SEZ 1 Regional The NMBMM 2 (Inter) Nationally or beyond 3 national B. Intensity– the magnitude of the impact in relation to the sensitivity of the receiving environment None 0 Low Site-specific and wider natural and/or social functions and 1 processes are negligibly altered Medium Site-specific and wider natural and/or social functions and 2 processes continue albeit in a modified way High Site-specific and wider natural and/or social functions or 3 processes are severely altered C. Duration– the time frame for which the impact will be experienced None 0 Short-term Up to 2 years 1 Medium- 2 to 15 years 2 term Long-term More than 15 years 3

The combined score of these three criteria corresponds to a Consequence Rating (Table 18).

Table 18: Method used to determine the Consequence Score Combined Score 0 – 2 3 – 4 5 6 7 8 – 9 (A+B+C) Consequence Rating Not Very Low Medium High Very significant low high

Once the consequence has been derived, the probability of the impact occurring is considered using the probability classifications presented in Table 19.

Table 19: Probability Classification Improbable < 40% chance of occurring Possible 40% - 70% chance of occurring Probable > 70% - 90% chance of occurring Definite > 90% chance of occurring

The overall significance of impacts is determined by considering consequence and probability using the rating system prescribed in Table 20.

19 Table 20: Impact Significance Ratings Significance Rating Possible Impact Combinations Consequence Probability Insignificant Very Low & Improbable Very Low & Possible Very Low Very Low & Probable Very Low & Definite Low & Improbable Low & Possible Low Low & Probable Low & Definite Medium & Improbable Medium & Possible Medium Medium & Probable Medium & Definite High & Improbable High & Possible High High & Probable High & Definite Very High & Improbable Very High & Possible Very High Very High & Probable Very High & Definite

Finally, the status of the impacts are either positive or negative impact and the confidence in the assigned impact significance rating (Table 21).

Table 21: Impact status and confidence classification Status of impact Indication whether the impact is adverse (negative) or + ve (positive – a ‘benefit’) beneficial (positive). – ve (negative – a ‘cost’) Confidence of assessment The degree of confidence in predictions based on available Low information, specialist judgment and/or specialist Medium knowledge. High

5.1.4 Summary of Impacts

Using the scoring system described above, the potential impact of emissions from the proposed 200 MW Mulilo-Total Power Plant is assessed. The cumulative impacts of the proposed project with existing sources are also assessed. The respective impact summary scores are captured in Table 22.

20 The proposed 200 MW Mulilo-Total Power Plant:

• For SO2, NO2 and PM10, the extent of the potential impact is local and limited to the SEZ. • The predicted ambient concentrations resulting from the power plant emissions are very low and the intensity is rated as low for all pollutants. • Although the intensity is low or irrelevant, any impact will endure for the life of the power plant. The duration is therefore long term. • The consequence of the potential impact is therefore very low for all pollutants. • As the intensity is low, the probability of air quality impacts from the power plant are improbable for all pollutants. • The significance rating is therefore considered to be insignificant for all pollutants. • Air pollutants may have negative health effects even at low concentration. The status of the impact is therefore negative. • The assessment is based on representative data and has been conducted by an experienced team. A high level of confidence is placed on the findings of the assessment.

The proposed 1 000 MW Zone 13 Power Plant (uMoya-NILU, 2021a):

Cumulative effect of the proposed 200 MW Mulilo-Total Power Plant:

• For SO2, NO2 and PM10, the extent of the potential impact is local and limited to the SEZ. The cumulative effect in the SEZ will therefore be very small or negligible and is therefore also regarded as local. • The predicted ambient concentrations resulting from the power plant emissions are very low and the intensity is rated as low for all pollutants. It is highly unlikely that they will contribute to exceedances of the ambient standards. The cumulative effect in the SEZ will be very small or negligible and is therefore also regarded as low. • The assessment is based on representative data and has been conducted by an experienced team. A high level of confidence is placed on the findings of the assessment.

21 Cumulative effect of the other proposed gas-to-power project in the Coega SEZ

• The predicted maximum concentrations of SO2, NO2 and PM for the proposed Karpowership project in the port of Ngqura is predicted to be very low relative to the NAAQS. In all cases the predicted maximum increase is over the Coega SEZ. The 3 3 maximum predicted annual concentrations are 0.09 µg/m for SO2, 1.8 µg/m for NO2 3 and 0.4 µg/m for PM10 (uMoya-NILU, 2020).

• The predicted maximum concentrations of SO2, NO2 and PM for the proposed 3 000 MW Coega gas-to-power project is predicted to be very low relative to the NAAQS. In all cases the predicted maximum increase is over the Coega SEZ. The maximum 3 3 predicted annual concentrations are 1.2 µg/m for SO2, 1.5 µg/m for NO2 and 0.3 3 µg/m for PM10 (uMoya-NILU, 2021a). • The proposed Engie gas-fired power plant will result in very low ambient

concentrations of SO2, NO2 and PM relative to the NAAQS. In all cases the predicted maximum increase will occur over the Coega SEZ (uMoya-NILU, 2021b).

• For SO2, NO2 and PM10, the extent of the potential impact of the other gas-to-power projects is local and limited to the SEZ. The contribution will not significantly increase the ambient concentrations and will not result in exceedances of the NAAQS. The cumulative effect in the SEZ will therefore be very small or negligible and is therefore also regarded as low. • The predicted ambient concentrations resulting from the power plant emissions are

very low and the intensity is rated as low for NO2 and irrelevant for the other pollutants. It is highly unlikely that they will contribute to exceedances of the ambient standards. The cumulative effect of the gas-to-power projects will be very small or negligible and is therefore also regarded as low. • The cumulative assessment of the other gas-to-power projects is based on their respective AIRs.

22 Table 22: Air quality Impact Assessment summary scores Description Pollutants Extent Intensity Duration Consequence Probability Significance Status Confidence Reversibility

SO2 N/A N/A N/A N/A N/A N/A N/A N/A N/A 200 MW Mulilo-Total Power NO2 1 1 3 Very low Improbable Insignificant -ve High Yes Plant PM10 1 1 3 Very low Improbable Insignificant -ve High Yes

SO2 1 1 3 Very low Improbable Insignificant -ve High Yes 1 000 MW Zone 13 Power NO2 1 1 3 Very Low Improbable Insignificant -ve High Yes Plant PM10 1 1 3 Very low Improbable Insignificant -ve High Yes

SO2 N/A N/A N/A N/A N/A N/A N/A N/A N/A 200 MW Mulilo-Total Power NO2 1 1 3 Very low Improbable Insignificant -ve High Yes Plant with existing sources PM10 1 1 3 Very low Improbable Insignificant -ve High Yes

SO2 N/A N/A N/A N/A N/A N/A N/A N/A N/A 200 MW Mulilo-Total Power

Plant with other gas-to- NO2 1 1 3 Very Low Improbable Insignificant -ve High Yes power projects PM10 1 1 3 Very low Improbable Insignificant -ve High Yes

23 5.3 Analysis of Emissions’ Impact on the Environment

This AIR has focused on potential human health impacts. An assessment of the atmospheric impact of the facility on the environment was therefore not undertaken as part of this AIR.

6. COMPLAINTS

Not relevant to this AIR as this is a proposed facility.

7. CURRENT OR PLANNED AIR QUALITY MANAGEMENT INTERVENTIONS

Air quality management interventions during construction will aim to control wind and vehicle entrained dust.

Air quality management interventions during operations are not necessary considering the clean fuel, low emissions of the engine design and the low impact of the project on air quality.

8. COMPLIANCE AND ENFORCEMENT ACTIONS

Not relevant to this AIR as this is a proposed facility.

9. SUMMARY AND CONCLUSION

24 It is noteworthy that the NOX emission for the proposed 200 MW Mulilo-Total Power Plant is

35% of the emission that was used to assess the proposed 1 000 MW plant. The PM10 emission is just 15% of the emission of the proposed 1 000 MW plant.

In comparing the predicted ambient concentrations resulting from the proposed 1 000 Power Plant and the proposed 200 MW Mulilo-Total Power Plant, the following points are relevant: • The proposed location for the 200 MW Mulilo-Total Power Plant is on a portion of the proposed 1 000 MW Zone 13 Power Plant site. • The stack heights for the proposed 200 MW Mulilo-Total Power Plant will be somewhat lower than the proposed 1 000 MW Power Plant. • There is a linear relationship between emissions and ambient concentrations in dispersion modelling. In other words, an increase in emission of 10% will result in an increase in ambient concentrations of 10%. Similarly, a decrease of 10% in emissions will result in a decrease of 10% in the predicted ambient concentrations.

The SO2 emission from the proposed 200 MW Mulilo-Total Power Plant is negligible. The proposed 200 MW plant will not add significantly to the existing ambient SO2 concentrations.

The NOX emission of the proposed 200 MW Mulilo-Total Power Plant is 35% of the emission of the proposed 1 000 MW Power Plant. The equivalent maximum annual NO2 concentration 3 3 is 0.3 µg/m . This is very low relative to the NAAQS of 40 µg/m for NO2. The proposed 200

MW plant will not add significantly to the existing ambient NO2 concentrations.

The PM10 emission of the proposed 200 MW Mulilo-Total Power Plant is 15% of the emission of the proposed 1 000 MW Power Plant. The equivalent maximum annual PM10 concentration 3 3 is 0.006 µg/m . This is very low relative to the NAAQS of 75 µg/m for PM10. The proposed

200 MW plant will not add significantly to the existing ambient PM10 concentrations.

It is the opinion of the assessor that the proposed 200 MW Mulilo-Total Power Plant will not have a significant negative impact on ambient air quality. From an air quality perspective it is recommended that the application be approved.

10. REFERENCES

DEA (2010): Listed Activities and Associated Minimum Emission Standards identified in terms of Section 21 of the Air Quality Act, Act No. 39 of 2004, Government Gazette 33064, Notice No. 248 of 31 March 2010. DEA (2013): Listed activities and associated Minimum Emission Standards identified in terms of Section 21 of the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004), Government Gazette Notice No. 893 of 22 November 2013. DEA (2019): Listed activities and associated Minimum Emission Standards identified in terms of Section 21 of the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004), Government Gazette Notice No. 42472, Notice No.GN687 of 22 May 2019.

25 DEA (2020): Listed activities and associated Minimum Emission Standards identified in terms of Section 21 of the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004), Government Gazette Notice No. 43174, Notice No.GN657 of 27 March 2020. Sutkowski, M. (2011): Wärtsilä 18V50SG – the world’s biggest four-stroke spark-ignited gas engine, PTNSS–2011-SC-046, file:///C:/Users/MARKZU~1/AppData/Local/Temp/sutkowski_wartsila_ss_3_2011.pdf uMoya-NILU (2020): Atmospheric Impact Report Atmospheric Impact Report for the proposed Karpowership Project at Ngqura (Coega) Port, Report No. uMN095-2020, June 2020. uMoya-NILU (2021a): Atmospheric Impact Report in support of the Proposed Coega 3000 MW Integrated Gas-to-Power Project, Zone 13: Inland Power Station, Report No. uMN094- 2020, February 2021 uMoya-NILU (2021b): Atmospheric Impact Report in support of the Proposed Engie 200MW Gas to Power Project in the Coega Special Economic Zone, Report No.: uMN016-21, February 2021.

11. FORMAL DECLARATIONS

26 DECLARATION OF ACCURACY OF INFORMATION – APPLICANT

Name of Enterprise: uMoya-NILU Consulting (Pty) Ltd

Declaration of accuracy of information provided:

Atmospheric Impact Report in terms of Section 30 of the Act

Signed at Durban on this 11th day of February 2021.

______SIGNATURE

Managing Director – uMoya-NILU Consulting CAPACITY OF SIGNATORY

27 DECLARATION OF INDEPENDENCE – PRACTITIONER

Name of Practitioner: Mark Zunckel

Name of Registered Body: South African Council for Natural Scientific Professionals

Professional Registration Number: 400449/04

Declaration of independence and accuracy of information provided:

Atmospheric Impact Report in terms of Section 30 of the Act

Signed at Durban on this 11th day of February 2021

______SIGNATURE

Managing Director – uMoya-NILU Consulting CAPACITY OF SIGNATORY